Attachment 1996Mobile letter ju

This document pretains to SAT-L/A-19941116-00070 for Launch Authority on a Satellite Space Stations filing.

IBFS_SATLA1994111600070_1081071

                                          SHAW PITTMAN                                                    RECEIVED
                                        POTTS sTROWBRIDCE
                                        A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS                    JUL 3 1 1996
                                                                                                                                    mission
                                                     2300 N Street, N.W.
                                                Washington, D.C. 20037—1128                          Federal Communications Com
                                                        202.663.8000                                          Office of Secratary
                                                    Facsimile 202.663.8007

JILL ABESHOUSE STERN, P.C.                                                                             900 Third Avenue
         202.663.8380                                                                            New York, New York 100224728
  jill_stern@shawpittman.com




                                                       July 31, 1996




   Mr. William F. Caton
   Secretary                                                                                »                  #
   Federal Communications Commission                                                               Rece‘ved
   1919 M Street, N.W.
   Washington, D.C. 20554                                                                         AUC 0 2 1996
             Re:       Mobile Communications Holdings Inc.
                       File Nos. 11—DSS—P—91(6); 18 DSS—P—91(18);
                                                                                                     satme a: s
                                                                                            Wmmmcm lOnis              IYISIONY
                          —SC       A—95; 12—
                                ~L(AL~7FJsA              —A            p—95                     international Burea;,
   Dear Mr. Caton:

          On behalf of Mobile Communications Holdings, Inc. (MCHI), I am transmitting
   herewith an original and four copies of a "Request for Extension of Time" with respect to the
   above—referenced Big LEO application.

          Should there be any questions concerning this matter, kindly communicate with the
   undersigned.

                                                                Sincerely,




                                                                Jill     Abeshouse Stern

   Enclosures


                                                                                     RECEIVED
                                               Before the                                 JUL 3 1 1996
                        FEDERAL COMMUNICATIONS COMMISSION                       Federal Communications Commission
                                     Washington, D.C. 20554                               Office of Secratary



 In re Application of                                       )
                                                            )
                                                            )
 MOBILE COMMUNICATIONS                                      )    File Nos.11—DSS—P—91(6);
 HOLDINGS, INC.                                             )              18—DSS—P—91(18);
                                                            ))             11—SAT—LA—95;
                                                            )              12—SAT—AMEND—95
 For Authority to Construct, Launch, and Operate            )
 ELLIPSO® a Low Earth Orbit Satellite System                )
 to Provide Mobile Satellite Services in the                )                         i
 1610—1626.5 MHz/2483.5—2500 MHz Bands                      )                Recaived


                                                                             AUC 0 2 1996
                           REQUEST FOR EXTENSION OF TIME
                                                                               Sateliite ark.
                                                                   Redlssommunicsations Owisiont
                                                                        international Bureau
        Mobile Communications Holdings, Inc. ("MCHI"), by its attorneys, hereby requests a brief

extension of the deadline for applicants in the Big LEO proceeding to demonstrate financial quali—

fications from August 26, 1996 until and including September 16, 1996. In support whereof, the

following is shown.


           1. MCHI‘s application for authority to construct, launch and operate the ELLIPSO‘®

low—Earth orbit mobile satellite system has been pending with the Commission since November

1990. On January 31, 1995, the International Bureau deferred MCHI‘s application until January

1996 for submission of a supplemental financial showing, while simultaneously granting the appli—

cations of several large companies. On March 2, 1995, MCHI filed a "Consolidated Application

for Review and Request for Clarification" of the International Bureau‘s decisions by the full Com—

mission. By Memorandum Opinion and Order released January 26, 1996, the International


Bureau granted an extension of "the deadline for applicants in the Big LEO proceeding that have

not yet done so to demonstrate financial qualifications...until 60 days after the Commission re—

leases an order disposing of MCHI‘s Consolidated Application for Review." On June 27, 1996,

the Commission denied MCHI‘s Consolidated Application for Review," triggering an August 26,

    1996 deadline for demonstration of financial qualifications by parties that have not yet done so.


               2. The August 26, 1996 filing deadline established by release of the Commission‘s

June 27, 1996 Order occurs at the peak of the summer vacation period, during the week prior to

the Labor Day holiday. Compliance with the deadline will impose a hardship on the parties. In

particular, the late August deadline creates many practical inconveniences in securing corporate

action, including, for example, Board approvals and officer signatures, from the applicants and

their investors, which may be required to finalize financial documentation.


               3. A brief exfension of time, until and including September 16, 1996, will not harm

any party. The current filing deadline was exclusively determined, as far as we are aware, by re—

lease of the Commission‘s decision and is not compelled for any stated substantive or procedural

imperative.


              4.   Counsel to AMSC, Constellation, Motorola and TRW have all indicated, respec—

tively, that their clients have no objection to the requested extension of time. Counsel to

Loral/Qualcomm Partnership was advised of MCHI‘s intention to seek an extension of time, but

did not indicate LQP‘s position prior to the filing of this request.




U         Memorandum Opinion and Order, FCC 96—279, released June 27, 1996.

                                                    «2.


        For the foregoing reasons, it is respectfully requested that the Commission grant a brief

extension of time, until and including September 16, 1996, for the deferred Big LEO applicants

to demonstrate financial qualifications.




                                                      Respectfully submitted,

                                                     MOBILE COMMUNICATIONS
                                                     HOLDINGS, INC.


                                              By:    \*’Q-Q O/C'Qéflw %A
                                                      ill Abeshouse Stern



                                                      Shaw, Pittman, Potts & Trowbridge
                                                      2300 N Street, NW.
                                                      Washington, D.C. 20037—1128
                                                      (202) 663—8380
                                                      Its Attorneys



July 31, 1996


                                 CERTIFICATE OF SERVICE

       I, Felecia DeLoatch, do hereby certify that a true and correct copy of the foregoing docu—
ment was sent by first—class mail, postage prepaid, or hand—delivered, on this 3 1st day of July,
1996, to the following persons:


                *Donald Gips
                Chief, International Bureau
                Federal Communications Commission
                2000 M Street, NNW., Room 830
                Washington, D.C. 20554

               *John Stern, Esq.
               Senior Legal Advisor to
               International Bureau Chief
               Federal Communications Commission
               2000 M Street, NW., Room 800
               Washington, D.C. 20554

               Norman P. Leventhal, Esq.
               Raul R. Rodriguez, Esq.
               Stephen D. Baruch, Esq.
               2000 K Street, NW., Suite 600
               Washington, D.C. 20006—1809

               Robert A. Mazer, Esq.
               Vinson & Elkins
               1455 Pennsylvania Avenue, NW.
               Washington, D.C. 20004—2505

               William Wallace, Esq.
               Crowell & Moring
               1001 Pennsylvania Avenue, NW.
               Washington, DC 20004—2505

               Bruce D. Jacobs, Esq.
               Glenn S. Richards, Esq.
               Fisher Wayland Cooper Leader & Zaragoza, L.L.P.
               2001 Pennsylvania Avenue, NW., Suite 400
               Washington, D.C. 20006—1851


                    Lon C. Levin
                    Vice President and Regulatory Counsel
                    AMSC Subsidiary Corporation
                    10802 Parkridge Boulevard
                    Reston, VA 22091

                    Philip L. Malet, Esq.
                    Alfred Mamlet, Esq.
                    Steptoe & Johnson
                    1330 Connecticut Avenue, NW.
                    Washington, D.C. 20036




* Hand Delivered                             C              d

      337551—01 / DOCSDC1



Document Created: 2015-03-18 14:47:16
Document Modified: 2015-03-18 14:47:16

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