IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)

United States of America,	)

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

Plaintiff,	)

)

v.	)

)

SBC Communications, Inc. and	)

AT&T Corp.,	)

)

Defendants.	)

)

)

United States of America,	)

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

Plaintiff,	)

)

v.	)

)

Verizon Communications Inc. and	)

MCI, Inc.,	)

)

Defendants.	)

)

OPPOSITION OF THE UNITED STATES TO THE NEW JERSEY RATE COUNSEL'S "MOTION" TO MODIFY PROTECTIVE ORDERS

The United States opposes the New Jersey Division of Rate Counsel's "motion"1 to modify the Court's Protective Order entered on July 25, 2006 in relation to the unredacted Federal Communications Commission (FCC) Orders and to modify the pending proposed protective orders in relation to the United States' submission of materials. We object to Rate Counsel's motion on the grounds that (1) the Court has not granted it leave to participate in these proceedings in any manner; (2) it has not specified what information it proposes to submit so we have no way to judge the information's relevance; and (3) it appears to be asking the Court to relieve it of the restrictions on the use of confidential information imposed by the FCC and the New Jersey Board of Public Utilities as opposed to requesting such relief from those agencies or from the parties whose information it wishes to disclose.

Conclusion

The Court should deny the Rate Counsel's "motion" for modification of the Protective Order and subsequent protective orders.

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