Attachment grant

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

IBFS_SATMOD2008051600106_652433

                                                                                               WILMERHALE

                                                 June 24,2008                                      WillirmT.U
                                                                    F‘LED’ACCEPTED             +1 202 663 6725 (t)
Ms. Marlene H. Dortch                                                                             202 663 6363 (f)
                                                                                                   +1
Secretary                                                               JUN 2 4 2008 william.lakeOwilmerha~e.com
Federal Communications Commission
Washington, DC 20554

          Re:      FCC File No. SAT-MOD-2008051600106
                   MOTION FOR LEA KE 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.l’ On May 23,2008, the International Bureau placed the Modification
Application out for comment,’ and pursuant to section 25.154 of the Commission’s rules, 47
C.F.R. 6 25.154,petitions to deny the ModificationApplication were due to be filed no later than
June 23,2008.

        On June 23,2008, Globalstar was served by mail 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
Modification Application and served them upon Globalstar by mail. Ordinarily, Globalstar’s
opposition to these petitions would be due no later than July 3, 2008;2/ however, 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                               3
period for a response is 10 days or less, an additional 3 days (excluding holidays) will be                          \   ’

to all parties in the proceeding for filing a response.’941Accordingly, Globalstar’s
                                                                                                                     ‘ L
any petitions to deny the Modzjkation Application served on it by mail is not due
2008.



-1/
       Globalstar Licensee LLC - Application for Modification of Authority To Operate-?
Ancillary Terrestrial Component Authorities in the 1H2.4 GHz Bands (Call Sign S2 1 15) -@le
May 16,2008) (“Modijication Application”).
/’
       See Public Notice - Report No. SAT-00525,    Policy Branch Information, “Satellit
Station Applications Accepted for Filing” (rel. May 23,2008).
          See 47 C.F.R. 25.154(c).

          See 47 C.F.R.     9 1.401).


           Wilmer Cutler Pickering Hale and Dorr up, 1875 Pennsylvania Avenue Nw,Washington, DC 20006
Beijing   Berlin   Boston    Brussels   London   Los Angeles   New York   Oxford   Palo Alto   Waltham


June 24,2008
Page 2


        In order to avoid the need to file multiple oppositions to the petitions to deny the
ModiJicationApplication, 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 1.401). 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.

                                                     Respectlll y submitted,



                                                             +.
                                                     William Lake
                                                     Counsel to Globalstar Licensee LLC


cc:    Robert Nelson
       Andrea Kelly
       William Bell
       Jennifer Hindin
       Philip Bonomo
       Regina Keeney



Document Created: 2008-07-08 17:07:15
Document Modified: 2008-07-08 17:07:15

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