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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA


UNITED STATES OF AMERICA and    
STATE OF VERMONT,    

                  Plaintiffs,

                  v.

VERIZON COMMUNICATIONS INC. and   
RURAL CELLULAR CORPORATION,

                  Defendants.

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Case No. 1:08-cv-993-EGS

Filed: 12/11/2009



PLAINTIFF UNITED STATES' UNOPPOSED
MOTION TO MODIFY FINAL JUDGMENT

Plaintiff United States moves this Court for an order modifying Section IV.I of the Final Judgment entered in this case. The Final Judgment required defendants to sell wireless businesses in portions of three states, and allowed defendants to enter into a transition services agreement with the acquirer for a period of up to one year after the sale. Specifically, the first sentence of Section IV.I of the Final Judgment states:

At the option of the Acquirer(s) of the Divestiture Assets, defendants shall enter into a contract for transition services customarily provided in connection with the sale of a business providing mobile wireless telecommunications services or intellectual property licensing sufficient to meet all or part of the needs of the Acquirer(s) for a period of up to one year.

In accordance with the Final Judgment, defendants sold the wireless assets to AT&T Inc. ("AT&T"), and entered into a one-year transition services agreement with AT&T. The proposed modification would change Section IV.I to allow the term of the transition service agreement to be extended for a three month period to allow AT&T to complete the transition of a remaining

Plaintiff United States moves this Court for an order modifying Section IV.I of the Final Judgment entered in this case. The Final Judgment required defendants to sell wireless businesses in portions of three states, and allowed defendants to enter into a transition services agreement with the acquirer for a period of up to one year after the sale. Specifically, the first sentence of Section IV.I of the Final Judgment states:

At the option of the Acquirer(s) of the Divestiture Assets, defendants shall enter into a contract for transition services customarily provided in connection with the sale of a business providing mobile wireless telecommunications services or intellectual property licensing sufficient to meet all or part of the needs of the Acquirer(s) for a period of up to one year.

In accordance with the Final Judgment, defendants sold the wireless assets to AT&T Inc. ("AT&T"), and entered into a one-year transition services agreement with AT&T. The proposed modification would change Section IV.I to allow the term of the transition service agreement to be extended for a three month period to allow AT&T to complete the transition of a remaining

Dated: December 11, 2009 Respectfully submitted,


    _______________/s/________________
Hillary B. Burchuk (DC Bar # 366755)
Telecommunications & Media Enforcement
Antitrust Division
U.S. Department of Justice
450 5th Street, NW, Suite 7000
Washington, DC 20530
(202) 514-4853