United States' Motion for Leave to File a Supplemental Response

Date: 
Thursday, June 22, 2006
Document Type: 
Motions and Memoranda - Miscellaneous
This document is available in three formats: this web page (for browsing content), PDF (comparable to original document formatting), and WordPerfect. To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.


IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA



United States of America,    

                  Plaintiff,

                  v.

SBC Communications, Inc. and
AT&T Corp.,

                  Defendants.


United States of America,    

                  Plaintiff,

                  v.

Verizon Communications Inc. and   
MCI, Inc.,

                  Defendants.


|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|         

Civil Action No.: 1:05CV02102 (EGS)

Civil Action No.: 1:05CV02103 (EGS)

UNITED STATES' MOTION FOR LEAVE TO FILE A SUPPLEMENTAL RESPONSE

Despite ACTel's three voluminous prior filings (including sixteen exhibits) and the Court's direction that ACTel include in its May 16, 2006 filing any material it wanted the Court to consider, ACTel's June 6, 2006 reply brief includes 11 new exhibits, as well as new information, arguments and citations. The United States seeks leave to file the attached brief response to ACTel's reply in order to explain why these new arguments do not raise any significant issues regarding whether the proposed Final Judgments fall within the public interest. The response is limited to eight pages and only attempts to respond to new information or arguments made by ACTel.

Pursuant to the requirement of Local Rule 7(m), the United States represents that it has conferred with counsel for ACTel, AT&T, Comptel, and Verizon. AT&T, Comptel, and Verizon do not object to this Motion. ACTel stated that it "does not object . . . so long as the [United States] does not object to ACTel filing a response." Given ACTel's extensive prior filings, and the fact that the United States does not raise any new issues in its proposed Supplemental Response, the United States does not consent to another filing by ACTel.

    Respectfully submitted,
_______________/s/________________
Laury E. Bobbish
Assistant Chief

_______________/s/________________
Claude F. Scott, Jr. (D.C. Bar No. 414906)
Lawrence M. Frankel (D.C. Bar No. 441532)
Jared A. Hughes
Trial Attorneys

Telecom & Media Section
Antitrust Division
U.S. Department of Justice
1401 H Street, N.W., Suite 8000
Washington, D.C. 20530
(202) 514-5621
Attorneys for the United States

Attachments

Attachment 1: United States' Supplemental Response to ACTel's Reply
Attachment 2: [Proposed] Order Granting United States' Motion for Leave to File a Supplemental Response

Attachments: 
Updated June 30, 2015