Motion for Leave to File Supplemental Complaint

Date: 
Monday, December 6, 1999
Document Type: 
Motions and Memoranda - Miscellaneous
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA,

         Plaintiff,

                  v.

BELL ATLANTIC CORPORATION,
and GTE CORPORATION,

         Defendants.
____________________________________

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Civil No.: 1:99CV01119(LFO)

Filed: December 6, 1999

MOTION FOR LEAVE TO FILE SUPPLEMENTAL COMPLAINT

Plaintiff United States of America, by and through undersigned counsel, hereby moves this Court pursuant to Federal Rule of Civil Procedure 15(d), for leave to file the Supplemental Complaint attached to this Motion(1) and to add Vodafone AirTouch Plc as a defendant to this proceeding. For the reasons set forth in the accompanying Memorandum of Points and Authorities, the United States respectfully requests that this Court grant it leave to file the Supplemental Complaint because it will promote a complete adjudication of the dispute between the parties and will not cause any prejudice.

The United States discussed this Motion with John Thorne, counsel for defendant Bell Atlantic Corporation, Steven G. Bradbury, counsel for defendant GTE Corporation, and Brian D. Kidney, an authorized representative of Vodafone AirTouch Plc, by telephone on December 3, 1999. Defendants and Vodafone AirTouch Plc do not oppose this motion.

    Respectfully submitted,
  _______________/s/________________
Hillary B. Burchuk
D.C. Bar # 366755
Lawrence M. Frankel
D.C. Bar No. 441532
Susan Wittenberg
D.C. Bar No. 453692
Trial Attorneys
United States Department of Justice
Antitrust Division
Telecommunications Task Force
1401 H Street, N.W., Suite 8000
Washington, D.C. 20530
(202) 514-5621
Counsel for Plaintiff United States

Dated: December 6, 1999


1. Also attached to this Motion are a Stipulation and proposed Final Judgment that would resolve this matter.

Attachments: 
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Updated June 30, 2015