Attachment 1990Motion for Exten

1990Motion for Exten

MOTION submitted by Contel

Motion for Extension of Time

3199-01-02

This document pretains to SAT-MOD-19900830-00049 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD1990083000049_1060903

GCf 2 REF®EFIVED Domestic Facilities Division Satellite Radio Branch ‘OCT 2 3 1990 Before the FEDERAL COMMUNICATIONS COMMISSTON Federal Communications Commisgion Washington, D.C. 20554 Office of the Secretary In the Matter of NN NNNA NA NA NP AMERICAN SATELLITE COMPANY File No. 61—DSS—EXT—90 d/b/a Contel ASC Modification of Authorization to Construct, Launch, and Operate Contelsat—1 MOTION FOR EXTENSTITON OF TIME American Satellite Company d/b/a Contel ASC ("Contel ASC"), by its attorney, hereby requests an extension of time to respond to the Petition to Deny filed by American Telephone and Telegraph Company ("AT&T") on October 11, 1990 * in the proceeding captioned above. Pursuant to the Commission‘s Rules, Contel ASC‘s request is due on October 24, 1990. Contel ASC respectfully asks that the due date for its pleading be extended for one week, until October 31, 1990 . * in making this request, Contel ASC reserves its right to object to AT&T‘s Petition on procedural grounds. In its public notice released September 12, 1990 (Report No. DS—1003), the Common Carrier Bureau specified that comments on Contel ASC‘s application were due on October 3. Since AT&T did not make its filing until October 11, Contel ASC contends that AT&T‘s Petition is untimely.

Contel ASC is requesting this extension of time because of the press of other business. As the Commission knows, Ccontel Corporation and GTE Corporation have entered into a definitive agreement pursuant to which the parties will, subject to Commission approval, merge their operations. This proposed transaction has generated a considerable amount of additional work for Contel ASC‘s staff and thus has made it difficult to attend to other matters in a timely manner. Contel ASC notes that since the subject of this proceeding is the construction schedule for Contelsat—1, no other party is materially affected by the short delay Contel ASC requests. Nevertheless, Contel ASC has consulted with AT&T‘s counsel on this matter. AT&T‘s counsel has advised Contel ASC that he has no objections to Contel ASC‘s request. For these reasons, grant of a one—week extension of time in which to respond to AT&T‘s Petition to Deny will

serve the public interest. As such, Contel ASC respectfully urges the Commission to grant this request. Respectfully Submitted, AMERICAN SATELLITE COMPANY d/b/a Contel ASC ~ o M. Griffin i;ZhAttorney ézz/ 555—13th St. NW Suite 480 West Washington, DC 20004 202—383—8 704 October 23, 1990

CERTIFICATE OF SERVICE I, Larry L. Hartwig, hereby certify that a true copy of the foregoing "Motion for Extension of Time" was served this 23rd day of October, 1990 by first class mail, postage prepaid, upon the parties listed below: Francine J. Berry David P. Condit Richard F. Hope AT&T 295 North Maple Avenue Basking Ridge, NJ 07920 x) Th By : Cijfry‘L. Hartw1g


Document Created: 2014-09-11 11:54:50
Document Modified: 2014-09-11 11:54:50
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