Florida's Unopposed Motion for Extension of Time to

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					1000211100022-TP AT&T Florida's Unopposed Motion for Extension of Time to Respond to Motions IO                             ~
                                                                                                             u i s i i i i ~, .
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    Sent:          Thursday, March 04, 2010 9:30 AM
    To:            Filings@psc.state.R.us
    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
    Importance:    High
    Attachments: DOC001.PDF

A       Vickie Woods
        BellSouth Telecommunications, Inc. d/b/a AT&T Florida
        150 South Monroe Street
        Suite 400
        Tallahassee, Florida 32301
        (305) 347-5560
       -vfI979@att.com

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
to Dismiss

       and/or Stay, Counterclaim and Requests for Oral Argument

.pdf


<<DOC001.PDF>>




3/4/2010
atat
 Manuel A. turdIan
 G m Attcfnw
  m l




                                   March 4.2010


 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,
                                      f
          W F I o r t d a Mainst LlkConmx Telrcom, LLC Wkla
          Swlftel, LLC

          Q&
           &&         I-
                      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
 of Service.




 cc:     AllpaNesofrecQrd
         Gfegory R. Follenebee
         Jeny D. Hendrlx
         E. Earl Edenflsid, Jr.
NewPhane, Ino.
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
AlCermSrn &ntlbrRtt
108 East College Avenue
SUHe 1200
Tallehasaee, FL 32301
             BEFORETHE FLORJDA PUBLIC SERVICE C o ~ s S I o N

  re:
~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
                          Inc.
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
                                                                      ac
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
            ims
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
                       ae
                                       ae
and P t t o for Relief and to Set Due D t to Respond to AT&T Florida’s Motion to
     eiin

Consolidate. On February 8,2010, the Prehedng officer granted the M O ~ ~ O Morder
                                                                          via

NOS.PSC-lo-0074-PCO-TP and PSC-lO-007S-PCbTP.

1
      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.
                                                   o
       3.                                       n
               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

                                e
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
0rdmN0~.

       4.      On February 25,2010, LifeConnex and New Phone fld Motions to
                                                              ie

D s i s andor Stay, Answers, A m a t i v e Defenses and Counter-Claims against AT&T
 ims

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
                                          lrd'
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
            fie
LifeConnex and Newphone's Motions to Dismiss and/or Stay, Counter-claims and

Requests for Oral Atgumat until April 9,2010.




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