Attachment Motion

Motion

MOTION TO ACCEPT LATE FILED COMMENTS submitted by Satamatics, Inc. ("Satamatics")

Motion

2006-02-28

This document pretains to SES-MFS-20051202-01665 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2005120201665_485498

RECEIVED Fes 2 8 2006 Before the FEDERAL COMMUNICATIONS COMMINSIONmnicatow nsm Washington, D.C. 20554 Weed sn In the Matter of Satamatics, Inc. File No. SES—MFS—20051202—01665 Application for Modification of Blanket (Call Sign ©020074) License to Operate Mobile Earth Terminals With Inmarsat 4F2 at 52.75° W.L. RECEIVED To: International Bureau MaR 0 2 2006 Satelte Dvision Intermational Bureau MOTION TO ACCEPT LATE—FILED REPLY Satamatics, Inc. (*Satamatics") hereby filesthis Motion to Accept a Late—Filed Reply to the Opposition to Motion to Strike (*MSV Opposition") filed by Mobile Satellite Ventures Subsidiary LLC(*MSV") in the above—referenced application ("Satamaties Modification Application®). The deadline for Satamatics to file ts Reply to the MSV Opposition was February 27, 2006. While every effort was made to file the Reply with the Commission on February 27, 2006, the Reply was not filed on February 27, 2006 due to an inadvertent miscommunication with the messenger service delivering the pleading to the Commission. Accordingly, Satamaties is fling the Reply today, February 28, 2006, along with this Motion. Satamaties recognizes that late—filed pleadings are not routinely accepted by the Commission without good eause. Satamaties respectfully submits that the delay in filing the Reply with the Commission was inadvertent, and not intended to somehow deceive the Bureau, or MSV." Further,there has not been undue prejudice to MSV —— a copy ofthe Reply was in faet ‘ See Inthe Matter ofLockheed Martin Corporation et a., 18 FCC Red. 16605, 16611 (2003) (dismissing a late—filed reply where it appeared a party intentionally filed its reply late, intentionally did not seek leave to file a ate—filed pleading and did not serve the reply on parties to the proceeding).

sent by first class mail postage prepaid on February 27,2006 to MSV. Further,the Commission‘s Rules do not contemplate an additional pleading by MSV in response to this Reply. As a result, the one day delayin filing this Reply has not hindered or affected MSV‘s ability to filea pleading in this matter. In contrast,rejecting the Reply would result in an incomplete record in this matter." Satamaties respectfully requests that ts late—filed Reply be accepted by the Bureau. Acceptance ofthe Reply will not undulyprejudice MSV and will ensure a complete record in this matter. Respectfully submitted, Satamaties, Inc, A_l EL Alfred M. Mamlet Mare A. Paul Brendan Kasper Steptoe & Johnson LLP 1330 Connecticut Avenue, NW Washington, DC 20036 (202) 429—3000 Counselfor Satamatics, Inc. February 28, 2006 * Late—filed pleadings have been accepted for purpose of ereating a complete record in a proceeding. See, eg. In the Matter ofLoral Satellite, Inc. and Loral Spacecom Corporation et al, 19 FCC Red. 2404, 2411 (2004) (accepting a late—filed petition filed with the Intermational Bureau in order to create a "full and complete factual record");see also Jn the Matter of Application of Verizon Hawaii, Inc. et al. 19 FCC Red. 24110, 24111 (2004) (finding that the Wireless Bureau has "discretion to acceptlte—filed pleadings to develop a complete record"). 3

CERTIFICATE OF SERVICE 1, Mare A. Paul, an attomney with the law firm of Steptoe & Johnson LLP, hereby certify that on this 28th day of February, 2006, served a true copy of the foregoing Motion by first class mail, postage pre—paid (or as otherise indicated) upon the following: Robert Nelson® Andrea Kelly* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12"Street, S.W. Washington, DC 20554 Washington, DC 20584 Howard Gribof® Karl Kensinger® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12"Street,SW. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnek® John Martin® Interational Burcau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street,SW Washington, DC 20554 Washington, DC 20554 Stephen Duall® Jennifer A. Manner International Bureau Viee President, RegulatoryAffairs Federal Communications Commission Mobile Satellite Ventures Subsidiary LLC 445 12" Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 James Ball® Bruce D. Jacobs Interational Bureau David S. Konezal Federal Communications Commission Pillsbury Winthrop ShawPittman LLP 445 12" Street, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1 128

JoAnn Ekblad* John P. Janka, Interational Bureau Jeffrey A. Marks Federal Communications Commission Latham & Watkins LLP 445 12" Street, S.W. 555 Eleventh Street, N.W., Suite 1000 Washington, DC 20554 Washington, D.C. 20004 Diane J. Comell ‘Viee President, Government Affairs Inmarsat,Inc. 1100 Wilson Blvd, Suite 1428 Arlington, VA 222 * by Hand Delivery


Document Created: 2006-03-02 12:23:04
Document Modified: 2006-03-02 12:23:04
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