Attachment motion

This document pretains to SAT-MOD-20080516-00106 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008051600106_650452

WILMERHALE Ms. Marlene H. Dortch +1 202 663 6363 (f) Secretary JUN 2 4 2008 william.lakeQwilmerhale.com Federal Communications Commission Federal CommunicationsCommission Office of the Secretary Washington, DC 20554 Re: FCC File No. SAT-MOD-20080516-00106 MOTION FOR LEA TO FILE CONSOLIDATED OPPOSITION Dear Ms. Dortch: On May 16,2008, Globalstar Licensee LLC (“Globalstar”) filed an application in the above-referenced proceeding seeking modification of its Ancillary Terrestrial Component (“ATC”) auth0rity.I’ On May 23,2008, the International Bureau placed the Modzjication Application out for comment,21and pursuant to section 25.154 of the Commission’s rules, 47 C.F.R. 5 25.154, petitions to deny the Modification Application were due to be filed no later than June 23,2008. On June 23,2008, Globalstar was served by email with pleadings filed by Iridium Satellite LLC and the U.S. GPS Industry. In addition, Globalstar has been informed that at least one party (Sprint Nextel Corporation) and potentially others have filed petitions to deny the Modijkation Application and served them upon Globalstar by mail. Ordinarily, Globalstar’s opposition to these petitions would be due no later than July 3, 2008;31however, section 1.4(h) of the Commission’s rules provides that “[i]f a document is required to be served upon other parties by statute or Commission regulation and the document is in fact served by mail . .. and the filing period for a response is 10 days or less, an additional 3 days (excluding holidays) will be allowed to all parties in the proceeding for filing a response.”4’ Accordingly, Globalstar’s opposition to any petitions to deny the Modification Application served on it by mail is not due until July 9, 2008. ___ ____ I/ Globalstar Licensee LLC - Application for Modification of Authority To Operate Ancillary Terrestrial Component Authorities in the 1.6/2.4 GHz Bands (Call Sign S2115) (filed May 16,2008) (“ModificationApplication”). 21 See Public Notice - Report No. SAT-00525, Policy Branch Information, “Satellite Space Station Applications Accepted for Filing” (rel. May 23,2008). ’ See 47 C.F.R. 25.154(c). “ See 47 C.F.R. 5 1.4(h). Wilmer Cutler Pickering Hale and Dorr LLP, 1875 Pennsylvania Avenue NW, Washington, D C 20006 Beijing Berlin Boston Brussels London Los Angeles New York Oxford Palo Alto Waltham Washington

WILMERHALE June 24,2008 Page 2 In order to avoid the need to file multiple oppositions to the petitions to deny the Modification Application, Globalstar hereby requests leave to file a consolidated opposition to the pleadings submitted in this proceeding no later than July 9,2008, the date on which its opposition to the petitions served on it by mail is due. See 47 C.F.R. 0 1.4(h). Establishment of a consolidated reply date will not harm any party to this proceeding and will serve the public interest by avoiding the need for Globalstar to file, and the Bureau to consider, repetitive pleadings responding to the petitions. Globalstar has conferred with counsel for Iridium and the U.S. GPS Industry Council and they have informed Globalstar that they do not object to this request. Respectfully submitted, william -1.. Lake Counsel to Globalstar Licensee LLC cc: Robert Nelson Andrea Kelly William Bell Jennifer Hindin Philip Bonomo Regina Keeney


Document Created: 2008-06-25 15:01:23
Document Modified: 2008-06-25 15:01:23
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