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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)

OPPOSITION OF THE UNITED STATES TO MICHAEL LOVERN'S
MOTION FOR LEAVE TO FILE MOTION FOR RECONSIDERATION

The United States opposes Michael Lovern's motion for leave to file a motion for reconsideration pursuant to Rule 60(b) (docketed July 20, 2006) and his motion for reconsideration. It is not clear which, if any, judgment or order Mr. Lovern seeks to have the Court reconsider. (To the extent his motion for reconsideration relates to the Court's July 7, 2006 scheduling order for the July 12, 2006 hearing, it is now moot.) Nevertheless, Mr. Lovern has not demonstrated that reconsideration is justified under any part of Rule 60(b), and accordingly the motion should be denied. In addition, the United States stands on the arguments it previously has made in opposition to Mr. Lovern's participation in these proceedings. See Opposition of the United States to Michael Lovern, Sr.'s Motion for Amicus Curiae and Intervenor Status (filed May 23, 2006). The United States' primary objection to Mr. Lovern's participation is that his concerns regarding the Intercompany Settlement System (ISS) have nothing to do with the proposed Final Judgments, the harm alleged in the Complaints, or even the mergers themselves. Therefore, his participation, as an intervenor or amicus curiae, will not assist the Court in any way in making the public interest determination that is before the Court.

Conclusion

The Court should deny Mr. Lovern's motion for leave to file a motion for reconsideration and should deny Mr. Lovern's motion for reconsideration.

    Respectfully submitted,


  _______________/s/________________
Laury E. Bobbish
Assistant Chief

_______________/s/________________
Claude F. Scott, Jr. (D.C. Bar No. 414906)
Matthew C. Hammond
Trial Attorneys

Telecommunications & 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


CERTIFICATE OF SERVICE

I hereby certify that on the 2nd day of August, 2006, I caused a copy of the foregoing United States' Motion for Entry of a Protective Order to be mailed, by U.S. mail, postage prepaid, to the attorneys listed below:

FOR VERIZON

John Thorne
Verizon Communications, Inc.
1515 North Courthouse Road
Arlington, Virginia 22201

Mark C. Hansen
Kellogg, Huber, Hansen, Todd, Evans
& Figel, P.L.L.C.
1615 M Street, N.W., Suite 400
Washington, DC 20036

FOR AT&T

Wm. Randolph Smith
Crowell & Moring LLP
1001 Pennsylvania Avenue, N.W.
Washington, D.C. 20004

FOR MOVANT MICHAEL LOVERN, SR.

Michael Lovern, Sr.
3713 Parke Drive
Edgewater, Maryland 21037
(206) 202-9074



  _______________/s/________________
Jared A. Hughes
Attorney
Telecommunications & Media Section
Antitrust Division
U.S. Department of Justice
1401 H Street, N.W., Suite 8000
Washington, D.C. 20530