United States' Unopposed Motion for Leave to File Reply Memorandum of Thirty-Five Pages

Date: 
Wednesday, May 31, 2006
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.

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

                  Defendants.


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Civil Action No.: 1:05CV02102 (EGS)
United States of America,    

                  Plaintiff,

                  v.

Verizon Communications Inc. and   
MCI, Inc.,

                  Defendants.


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

UNITED STATES' UNOPPOSED MOTION FOR LEAVE TO FILE REPLY MEMORANDUM OF THIRTY-FIVE PAGES

The United States respectfully requests that the Court allow it to file its Reply to ACTel's Opposition to the United States' Motion for Entry of the Final Judgments. The proposed Reply consists of thirty-fivepages, which exceeds the twenty-five page limit for reply memoranda set forth in Local Rule 7(e) of this Court.

The United States' proposed Reply addresses two separate memoranda filed by ACTel: (1) the Memorandum of Points and Authorities in Support of ACTel's Motion for Amicus Curiae and Intervenor Status Pursuant to the Tunney Act and in Opposition to the United States' Motion for Entry of Final Judgments, filed May 5, 2006; and (2) ACTel's Supplemental Memorandum in Opposition to the United States' Motion for Entry of Final Judgments, filed May 16, 2006. Though the United States previously responded to ACTel's Motion for Amicus Curiae and Intervenor Status on May 15, 2006, its Response did not address the substance of ACTel's opposition to the United States' Motion for Entry of Final Judgments, because ACTel had yet to file its supplemental memorandum in accordance with this Court's minute order of May 10, 2006.(1) The United States now proposes to file a single thirty-five page Reply that will address the substance of both of ACTel's memoranda, rather than to file separate responses for each of them. Accordingly, the United States submits that its proposed Reply, while in excess of the page limits set forth in Local Rule 7(e), is not excessively lengthy.

Pursuant to the requirement of Local Rule 7(m), the United States represents that it has conferred with counsel for ACTel, AT&T, and Verizon, and that none of them oppose the granting of this motion.

    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


FOOTNOTES

1. See Resp. of the United States to ACTel's Motion for Amicus Curiae and Intervenor Status Pursuant to the Tunney Act, at 2 n.2.

Attachments: 
Updated June 30, 2015