Attachment Req for Acceptance o

This document pretains to SAT-LOA-19941116-00088 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1994111600088_973530

                                                                                                           RECEIVED
                                       Vinson&¥Elkins
                                             ATTORNEYS AT LaAW                                              MAR ‘ 6 1998

                                                VINSON & ELKINS LLP                                    P               d te   eer, mniading
                                            THE WILLARD OFFICE BUILDING                             Federal Communications Gommission
                                            1455 PENNSYLVANIA AVE., N.W.                                    Oftice of Secratary
                                         WASHINGTON, D.C. 20004—1008
                                              TELEPHONE (202) 639—6500
                                                 FAX (202) 639—6604

WRITER‘S TELEPHONE                                                                              g
   (202) 639—6755                                                        Fe cey [ele|
                                                                         es      'E‘   i   ;5




                                               March 16, 1998



                                                                         aaagis potcy BC S
Ms. Magalie R. Salas                                                     "imte!      Burgay
Secretary
Federal Communications Commission
1919 M Street, N.W., Room 222
Washington, DC 20554

         Re:         Final Analysis Communication Services, Inc.
                     File No. 25—SAT—P/LA—95; 7—SAT—AMEND—98
                     Request for Acceptance of Supplemental Comments

Dear Ms. Salas:

          Leo One USA Corporation ("Leo One USA"), by its counsel, hereby requests acceptance of
the attached supplemental comments concerning the above—referenced application of Final Analysis
Communications Services, Inc. ("Final Analysis"). Leo One USA recognizes that the Commission
is reluctant to accept supplemental comments beyond the normal comment period specified in the
public notice accepting for filing a particular application. Nonetheless, Section 1.45(c) of the
Commission‘s Rules, 47 C.F.R. § 1.45(c), explicitly authorizes the Commission to accept comments
outside the normal pleading cycle where the public interest will be served by such action. The
proposed supplemental comments of Leo One USA enhance the record in the above—referenced
matter by providing new information regarding the reorganization ofthe Russian launch industry and
the impact such reorganization may have on Final Analysis‘ ability to obtain Russian launch services
free of charge. This information may be of decisional significance with regard to the Commission‘s
consideration of the pending application of Final Analysis to be a Little LEO licensee.
Consequently, acceptance ofthese supplemental comments will advance the public interest and assist
the Commission‘s adjudication of this matter.

        Recent press reports indicate that portions of the above—referenced application may be
inaccurate. Specifically, these press reports raise serious questions as to the validity of Final
Analysis‘ representations regarding its financial qualifications made in its pending application. This
is precisely the type of situation which warrants acceptance of supplemental comments pursuant to
Section 1.45(c). The Commission has an obligation to obtain a complete record, and these
supplemental comments will assist that effort. Leo One USA has filed this information in a timely



         HOUSTON        DALLAS    WASHINGTON, D.C.      AUSTIN        moscow       LONDON           SINGAPORE


= Ms. Magalie R. Salas
 March 16, 1998
 Page 2



 fashion and anticipates that acceptance of these supplemental comments will in no way prejlidice
 Final Analysis‘ ability to ensure an accurate record exists before the Commission.

        For the foregoing reasons, Leo One USA Corporation requests acceptance of the attached
 supplemental comments.

                                             ‘ Respectfully submitted,



                                              2s\ Ngr
                                              Albert Shuldiner
                                              Counsel for Leo One USA Corporation


 Enclosure

 ce:      Regina Keeney
          Cassandra Thomas
          Daniel Connors
          All parties of record



Document Created: 2012-10-24 15:26:59
Document Modified: 2012-10-24 15:26:59

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