Request for Extended

PETITION submitted by Eutelsat S.A.

Extension Request

2017-12-26

This document pretains to SAT-LOA-20170524-00078 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017052400078_1320493

LMI Advisors 2550 M Street, NW Suite 345 Washington, D.C. 20037 Carlos M. Nalda T +1 571 332 5626 cnalda@lmiadvisors.com December 26, 2017 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Request To Extend and Consolidate Pleading Schedule of Eutelsat S.A., File Nos. SAT-LOA-20170524-00078 and SAT-AMD-20170613-00086, Call Sign S3015 Dear Ms. Dortch: Eutelsat S.A. (“Eutelsat”) respectfully submits this Request To Extend and Consolidate Pleading Schedule (“Request”) with respect to the above-referenced application, as amended (“Application”), of Intelsat License LLC (“Intelsat”). The Request is being filed contemporaneously with a Petition To Defer or Deny, In Part of Eutelsat (“Eutelsat Petition”).1 Iridium Satellite LLC (“Iridium”) has also filed a Petition to Deny with respect to the Intelsat Application (“Iridium Petition”).2 The Intelsat Application was the subject of two public notices – one for the C-band and Ku-band portion of the Application,3 and one a week later for the Ka-band amendment to the 1 Petition To Defer or Deny, In Part, of Eutelsat S.A., File Nos. SAT-LOA-20170524-00078 and SAT-AMD-20170613-00086, Call Sign S3015 (filed Dec. 26, 2017). 2 Petition To Deny of Iridium Satellite LLC, File Nos. SAT-LOA-20170524-00078 and SAT- AMD-20170613-00086, Call Sign S3015 (filed Dec. 22, 2017). 3See Policy Branch Information, Space Station Applications Accepted for Filing, Public Notice Report No. SAT-01284 (Nov. 24, 2017) (File No. SAT-LOA-20170524-00078).

Application.4 In addition, the Iridium Petition and the Eutelsat Petition were filed on different days, requiring a separate opposition/response to be filed 10 days from the filing date of each Petition and triggering separate petitioner reply dates under the Commission’s rules.5 To consolidate the pleading cycle and maximize the time available to interested parties and the Commission, Eutelsat requests adoption of a modified pleading schedule based upon the filing dates associated with the later-noticed amendment to the Intelsat Application. Specifically, Eutelsat suggests a due date of January 12, 2018 for any Intelsat opposition/response6 and a due date of January 22, 2018 for any petitioner reply.7 This modified pleading cycle would give the parties additional time to prepare responsive submissions and, if desired, an opportunity to file consolidated pleadings. It also would help avoid potential hardship for the Commission and interested parties in preparing and reviewing pleadings over the holiday period. The undersigned has consulted with counsel for Intelsat and Iridium and confirmed that these parties have no objection to this Request. As of the filing of the Request, there are no other interested parties to the proceeding. 4See Policy Branch Information, Space Station Applications Accepted for Filing, Public Notice Report No. SAT-01286 (Dec. 1, 2017) (File No. SAT-AMD-20170613-00086). 5 See 47 C.F.R. § 25.154. 6This date is 10 days from the due date for petitions/comments in File No. SAT-AMD- 20170613-00086, which falls on New Year’s Day, so they would be due January 2, 2018. 7 This date is five days after January 12, 2018, plus three days for service by mail, which falls on Saturday, January 20, 2018, so replies would be due the following Monday. 2

Grant of this Request would serve the public interest by consolidating an otherwise disparate pleading cycle and affording interested parties additional time to review filings and prepare responsive submissions in this proceeding. Respectfully submitted, Carlos M. Nalda LMI Advisors, LLC On behalf of Eutelsat S.A. 3

CERTIFICATE OF SERVICE I, Jennifer White, do hereby certify that on December 26, 2017, I served a true and correct copy of the Request To Extend Pleading Schedule of Eutelsat S.A. by first-class mail on the following: For Intelsat License LLC: Susan H. Crandall INTELSAT CORPORATION 7900 Tysons One Place McLean, VA 22102 Jennifer D. Hindin WILEY REIN LLP 1776 K Street, N.W. Washington, DC 20006 For Iridium Satellite LLC: Maureen C. McLaughlin IRIDIUM SATELLITE LLC 1750 Tysons Boulevard, Suite 1400 McLean, VA 22102 Scott Blake Harris HARRIS, WILTSHIRE & GRANNIS LLP 1919 M Street, NW, 8th Floor Washington, DC 20036 Jennifer White LMI Advisors, LLC 4


Document Created: 2017-12-26 17:29:22
Document Modified: 2017-12-26 17:29:22
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