1000211100022-TP AT&T Florida's Unopposed Motion for Extension of Time to Respond to Motions IO ~
u i s i i i i ~, .
Sent: Thursday, March 04, 2010 9:30 AM
Subject: i00021/i00022-TP AT&T Florida's Unopposed Motion for Extension of Time to Respond to Motions to
Dismiss and/or Stay, Counterclaim and Requests for Oral Argument
A Vickie Woods
BellSouth Telecommunications, Inc. d/b/a AT&T Florida
150 South Monroe Street
Tallahassee, Florida 32301
B Docket No.: 100021-TP: Complaint of BellSouth Telecommunications.
Inc. d/b/a AT&T Florida Against LifeConnex Telecom, LLC f/Wa Swiflel, LLC
Docket No. 100022-TP: Complaint of BellSouth Telecommunications,
Inc. d/b/a AT&T Florida Against Image Access, Inc. d/b/a New Phone
C. BellSouth Telecommunications, Inc. d/b/a AT&T Florida
on behalf of Manuel A. Gurdian
D. 5 pages total (includes letter, certificate of service and pleading)
E. BellSouth Telecommunications. Inc. d/b/a AT&T Florida's Unopposed Motion for Extension of Time to Respond to Motions
and/or Stay, Counterclaim and Requests for Oral Argument
Manuel A. turdIan
G m Attcfnw
Me. Ann Cole
OMce of the Commission Clerk
Florida Public Servlce Commlsabn
2540 Shumerd Oak Boulevard
Tallahassee, FL 323Q0-0850
021-fp: Complalnt o BellSouthTelocommunldonm,
W F I o r t d a Mainst LlkConmx Telrcom, LLC Wkla
O: Complaint ofBollSouth Telecommunicatlons,
Inc. dlbla ATBT Florfda Agalnst Image Access, Inc. d/b/a New Phone
Dear Me. Cole:
Enclosed is BellSouth Telecommunications, Inc. d/b/a AT&T Florida's
Unopposed Motion for Extension of Time to Respond to Motlons to Dismiss
andlor Stay, Counterclaims and Requests for Oral Argument, which we ask that
you fila in the captioned dockets.
Copies have been sewed to the partles shown on the ettached Certificate
Gfegory R. Follenebee
Jeny D. Hendrlx
E. Earl Edenflsid, Jr.
Mr. Jim R Dry
5566 Hlbn Avsnua, Sui& 415
Batan Rouge, LA Yo808
Tal. NO,(226) 2144412
fa%No. (2281 214-4111
M&hOW J. F&l
108 East College Avenue
Tallehasaee, FL 32301
BEFORETHE FLORJDA PUBLIC SERVICE C o ~ s S I o N
~n Complaint of BellSouth )
TelemmmUnicatiom, Inc. d/b/a AT&T ) Docket NO.100021-TP
Florida Against LifecOnnex Teleurm, LLC )
W a Swiftel, LLC 1
In re: Complaint of J3ellSouth ) Docket N0.100022-TP
T e l e c o m m u n i d o ~ d/b/a AT&T )
Florida Against Image Access, Inc. d/b/a ) Filed: M r h 4,2010
New Phone )
UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOhW
TO MOTIONS TO DISMISS AND/OR STAY, COUNTERCLAIMS AND
POTJESTS FOR ORAL ARGUMENT
BellSouth Telecommunications, Inc. d/b/a AT&T Florida (“AT&T Florida”),
pursuant to Rule 28-106.204, Florida Administrative Code, hereby files this Unopposed
Motion for Extension of Time to Respond to Image Access, Inc.d/b/a NewPhone
(‘WewPhone’’) and LifecOnnex’ Telecom, LLC f/kfa Switfel, LLC‘s (“LifeConnex”)
Motions to D s i s and/or Stay, Counterclaims and Requests for Oral Argument. As
grounds therefor, AT&T Florida state as follows:
1. On January 8,2010, AT&T Florida filed Complaints and Petitions for
Relief in the above-referenced dockets against LifeConnex and NewPhone.
2. On February 3,2010, LifeConnex and NewPhone med Unopposed
Motions to Extend Due D t to File Responsive Pleadings to AT&T Florida’s Complaint
and P t t o for Relief and to Set Due D t to Respond to AT&T Florida’s Motion to
Consolidate. On February 8,2010, the Prehedng officer granted the M O ~ ~ O Morder
NOS.PSC-lo-0074-PCO-TP and PSC-lO-007S-PCbTP.
On F d m w y 2 S . 2010. LifsCwocx wed a Joinder inNewPtods Raspoaac in Opposirionto
AT&T Florida's Motion for consolidationand Motion t Dismiss andlor Stay in Docket No. lax122-Tp.
On Febtuary 22,2010, Lifecornex a d Newphone filed Unopposed
Motions to Extend Due Date to File Responsive Pleadings to AT&T Florida's Complaint
and Petition for Relief and to S t Due Date to Respond to AT&T Florida's Motion to
Consolidate. On Febnrary 23,2010, the Rehearing Officer granted the Motions via
PSC-10-0100-PCO-TP and PSC-10-0101-PCO-TP
4. On February 25,2010, LifeConnex and New Phone fld Motions to
D s i s andor Stay, Answers, A m a t i v e Defenses and Counter-Claims against AT&T
Florida and Requests for Oral Argument.
5. AT&T Florida's responses to the Motions to Dismiss and Requests for
Oral Argument are due March 4,2010. AT&T F o i a s response to the Counter-claims
is due on March 17,2010.
6. Due to the complexity of the issues, the need to investigate Lifecornex
and Newphone's counter-claims and the need to coordinateresponses in nine states,
AT&T Florida q u i r e s until April 9,2010 to respond to the afore-mentioned pleadings.
7. Counsel for LifeconncX and Newphone have advised that they are
unopposed to the requested extension.
WHEMFORE, for the foregoing reasons, AT&T Florida requests that the
Prehearing Ofcr grant this motion extending the due date of its responses to
LifeConnex and Newphone's Motions to Dismiss and/or Stay, Counter-claims and
Requests for Oral Atgumat until April 9,2010.