IN THE UNITED STATES DISTRICT COURT
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
Dated: December 6, 1999
1. Also attached to this Motion are a Stipulation and proposed Final Judgment that would resolve this matter.