Attachment 1997Motion for exten

1997Motion for exten

MOTION submitted by Constellation

Motion

1997-08-15

This document pretains to SAT-L/A-19941116-00075 for Launch Authority on a Satellite Space Stations filing.

IBFS_SATLA1994111600075_1061651

                                                                                                m 1#s"~ ATTiI~
                                          BEFORE THE                                         0| 1P 110  Ad
                                                                                             Uui’":.z yCl fne


          Federal Communications Commission
                                  WASHINGTON, D.C. 20554                                          w

                                                                                                  7

                                                      )
                                                                                  t a se t   tm    &9 3
In the Matter of

Application of Constellation Communications, Inc. )           File Nos: 17—DSS—P—91(48) — >
for Authority to Construct, Launch and Operate    )       _        &    CSS—91—013
A Low Earth Orbit Mobile Satellite System in the      )   —*8#=~ °_           ;
1610—1626.5/2483.5—2500 MHz Bands                     )               _ 11—SAT—LA—95
                                                      )                 159—SAT—AMEND—96


                            MOTION FOR EXTENSION OF TIME

       TRW Inc. ("TRW"), by its attorneys and pursuant to Section 1.46 of the Commission‘s

rules, 47 C.F.R. § 1.46 (1995), hereby requests that the Commission grant a one—week extension

of time, until February 11, 1997, for the filing of replies to the Consolidated Opposition of

Constellation Communications, Inc. ("Constellation Opposition") filed by Constellation on

January 23, 1997 in the above—captioned proceeding. Counsel for all parties of record in this

proceeding have consented to the extension requested by TRW herein.

       Constellation amended the above—referenced application on September 16, 1996, and a

Public Notice announcing the acceptance of that amendment for filing was issued by the

Commission on November 27, 1996 (Réport No. SPB—69). Between December 24 and 27, 1996,

TRW, L/Q Licensee, Inc. and Motorola Satellite Communications, Inc. filed petitions to dismiss

or deny Constellation‘s application. Because the Constellation Opposition was filed on January

23, 1997 — pursuant to a two—week extension of time granted to Constellation by the Satellite

and Radiocommunication Division — replies to that Opposition would normally be due on

February 4, 1997. See 47 C.F.R. §§ 25.154(d), 1.4 (1995).

       The Constellation Opposition contains numerous points that must be addressed in detail,


                                                 —2

including many new documents regarding Constellation‘s application that have never previously

been submitted to the Commission or made available for public review. TRW believes that grant

of the requested one—week extension of time will serve the public interest by enabling the

Commission to compile a complete record with which to evaluate Constellation‘s pending

application. TRW also believes that grant of the instant motion will have no significant impact on

any of the other parties to this proceeding.

       For the foregoing reasons, TRW requests an extension of time until February 11, 1997,

for the filing of replies to the Constellation Opposition.




                                                        Respectfully submitted,

                                                        TRW Inc.



                                                        m .O J<——
                                                             Norman P. Leventhal
                                                             Stephen D. Baruch
                                                             Walter P. Jacob

                                                             Leventhal, Senter & Lerman
                                                             2000 K Street, NW., Suite 600
                                                             Washington, D.C. 20006
                                                             (202) 429—8970

January 29, 1997                                        Its Attorneys


                                CERTIFICATE OF SERVICE

               I, Bernice Duckett certify that a copy of the foregoing "Motion for Extension of

Time" was mailed, first—class postage prepaid, this 29th day of January, 1997 to each of the

following:


                              *The Honorable Reed E. Hundt
                                Federal Communications Commission
                                1919 M Street, NW.
                                Room 814
                                Washington, DC 20554

                              *The Honorable James H. Quello
                               Federal Communications Commission
                                1919 M Street, NW.
                                Room 802
                                Washington, DC 20554

                              *The Honorable Rachelle B. Chong
                               Federal Communications Commission
                                1919 M Street, NW.
                                Room 844
                                Washington, DC 20554

                              *The Honorable Susan Ness
                                Federal Communications Commission
                                1919 M Street, NW.
                                Room 832
                                Washington, DC 20554

                              *Mr. Donald Gips
                                International Bureau
                               Federal Communications Commission
                               2000 M Street, NW
                               Room 827
                               Washington, DC 20554

                              * Mr. Thomas S. Tycz
                                International Bureau
                               Federal Communications Commission
                               2000 M Street, NW
                               Room 811
                               Washington, DC 20554

*By hand delivery


                                    12.


                    * Ms. Fern J. Jarmulnek
                      Chief, Satellite and Radiocommunication Division
                      International Bureau
                      Federal Communications Commission
                      2000 M Street, NW
                     Room 520
                     Washington, DC 20554

                     Philip Malet, Esq.
                     Alfred Mamlet, Esq.
                     Brent Weingardt, Esq.
                     Steptoe & Johnson, L.L.P.
                     1330 Connecticut Avenue, NW.
                     Washington, DC 20036

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

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

                     Robert A. Mazer, Esq.
                     Vinson & Elkins
                     1455 Pennsylvania Avenue, NW.
                     Suite 700
                     Washington, DC 20004

                     Jill A. Stern, Esq.
                     Shaw, Pittman, Potts & Trowbridge
                     2300 N Street, NW.
                     2nd Floor
                     Washington, DC 20037—1128



                                 ?WEWZ%
                                 Bernice Duckett

*By hand delivery



Document Created: 2014-09-16 18:03:52
Document Modified: 2014-09-16 18:03:52

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