Attachment 2001Mobile Annual re

This document pretains to SAT-L/A-19941116-00070 for Launch Authority on a Satellite Space Stations filing.

IBFS_SATLA1994111600070_1081085

LATHAM & WATKINS PAUL R. WATKINS 899 — 1973) ATTORNEYS AT LAW ; NEW yoRk ofrfice DANA LATHAM (1898 — 1974) 885 THIRD AVENUE, sUITE i000 1001 PENNSYLVANIA AVE., N.w. NEW YORK, NEW YORK ioo22—4802 CHICAGO suite 1300 PHONE (212) Soe—1200, FAX 751—4884 SEARS TOWER, SUITE s800 CHICAGO, ILLINOIS sosOs WASHINGTON, D.Cc. 20004—2505 TY El 650 TOWN CENTER DRIVE, SUITE 2000 ~ x ecsesresstECEIVED PHONE (3l2) 876—7700, FAX 9903—9767 COSTA MESA, CALIFORNIA S2626—1925 PHONE (714) §40—1235, FAX 755—8290 KONG sUuITE 2205A, 22ND FLOoOR DiEGO NO. 9 QUEEN‘S ROAD CENTRAL 7oi‘s" sTREET, suiTE 2100 HoNG kone PHONE + s52—2522—7886, FAx 2522—7006 JUN 2 3 1999 SAN DIEGO, CALIFORNIA sz2iol—si97 PHONE (619) 2se—1234, FAX so6—7419 LONDON OFFICGE AN_FR FFI ONE ANGEL COURT 505 MONTGOMERY STREET, SUITE 1900 LONDON EC2R 7HJ ENGLAND SAN FRANCISCO, CALIFORNIA 94111—2562 PHONE + 44—171—374 4444, FAX 374 4460 PHONE (415) 39|—0600, FAX se5—s8095 ANGELES vALLEY 633 WEST FIFTH STREET, SUITE 4000 75 WiLLOW ROAD LOS ANGELES, CALIFORNIA 90071—2007 MENLO PARK, CALIFORNIA 94025—3656 PHONE (213) 485—1234, FAX sol—8763 PHONE (€50) 328—4600, FAX 463—2600 Moscow Py ol LN EEi ULITSA GASHEKA, 7, 9th Froor * wup 20 cEcIL stREET, #25—02,/03,/04 moscow 123056, RUssiA THE EXCHANGE, SINGAPORE 049705 PHONE + 7—095 785—1234, FAX 7e5—1235 JJ PHONE + e5—s36—l161, FAX 536—1171 1/ m : NEW JERSEY OFFICE OFFICE ONE NEWARK CENTER, 6t FLOOR INFINI AKASAKA, 8—7—15, AKASAKA, MINATO—KU NEWARK, NEW JERSEY O7101—3174 TOKYO 107—0052, JAPAN PHONE (973) 639—1234, FAX 6390—7208 PHONE +813—3423—39070, FAX 3423—3071 BY HAND DELIVERY John I. Riffer Assistant General Counsel Administrative Law Division 9 HONJIHIIIY ULNT d he h 57 wnp Federal Communications Commission The Portals 445 12th Street, S.W. Washington, DC 20554 Re: Application of Mobile Communications Holdings, Inc. FIIC_NOS H‘DSS- P—91(6); 18—DSS—P—91(18); 11—SAT—LA—95; 12—SAT—AMEN@)98;ags- SAT—AMEND—96 Dear Mr. Riffer: This letter is submitted on behalf of Mobile Communications Holdings, Inc. ("MCHI") to supplement its October 19, 1998 and December 23, 1998 submissions responding . to the Office of General Counsel‘s August 19, 1998 request for information. MCHI has receritly learned of additional information which should not affect the General Counsel‘s prior determination that no violation of the Commission‘s ex parte rules had taken place. However, we are writing to correct a factual error contained in MCHI‘s prior submission. The General Counsel‘s August 19, 1998 letter requested information, inter alia, pertaining to a May 8, 1996 letter from David Thompson of Spectrum Astro to Kate Carr, Special Assistant to the President. In its October 19 submission, MCHI stated that MCHI had not solicited or encouraged Mr. Thompson to write the letter to Ms. Carr, and that it did not become aware that Mr. Thompson had written a letter to Ms. Carr until it was advised of this fact by the FCC. MCHI has recently learned that Mr. Helman saw and reviewed a draft of the DC_DOCS\219373.3 [W97]

LATHAM & WATKINS BY HAND DELIVERY John I. Riffer June 23, 1999 Page 2 letter from Mr. Thompson to Ms. Carr. Mr. Helman does not recall communicating with Mr. Thompson on this subject although he has recently seen a copy of the draft letter with his handwritten comments, raising a question in his mind as to the nature and extent of his involvement with this letter and whether he may have asked Mr. Thompson to use his contacts to support a change in policy issues such as the FCC‘s financial qualification standards. Although MCHI does not believe that these facts are material to the question of whether MCHI had violated the Commission‘s ex parte rules, MCHI is providing this information to the Commission to clarify Mr. Helman‘s and MCHI‘s prior statements concerning this matter. We have enclosed an amended declaration from Gerald Helman, which contains the information provided in this submission. Please do not hesitate to call us if you have any questions or concerns. Res: submitted, w /L/\ Eric L. Bernthal Teresa D. Baer Minh N. Vu of L¥ATHAM & WATKINS Counsel to Mobile Communications Holdings, Inc. DC_DOCS\219373.3 [W97]

| ‘LATHAM & WATKINS BY HAND DELIVERY John I. Riffer June 23, 1999 Page 3 co: Philip A. Malet, Esq. Marc A. Paul, Esq. Steptoe & Johnson 1330 Connecticut Ave., N.W. Washington, D.C. 20036—1795 William D. Wallace, Esq. Crowell & Moring 1001 Pennsylvania Ave., NW. Washington, DC 20004 Norman P. Leventhal, Esq. Walter P. Jacob, Esq. Leventhal, Senter & Lerman 2000 K Street, NW., Suite 600 Washington, D.C. 20006 Leslie Taylor, Esq. Leslie Taylor Associates 6800 Carlyna Court . Bethesda, Maryland 20817—4302 Lon C. Levin, Esq. Vice President & Regulatory Counsel AMSC Subsidiary Corporation 10802 Parkridge Boulevard Reston, Virginia 22091 Robert A. Mazer, Esq. Vinson & Elkins 1455 Pennsylvania Ave., N.W. Suite 700 Washington, D.C. 20006 DC_DOoC§\219373.3 [W97]

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 _/ NJRA NLZZANLZANZ In the Matter of File Nos. 11—DSS—P—91(6); 18—DSS— Application of Mobile Communications P—91(18); 11—SAT—LA—95; 12—SAT— Holdings, Inc. AMEND—95; 158—SAT—AMEND—96 SUPPLEMENTAL DECLARATION OF GERALD B. HELMAN I, Gerald B. Helman, hereby declare as follows: 1. _ I am the Vice President, International and Governmental Affairs of Mobile Communications Holdings, Inc. ("MCHI"). I have held this position since 1993. My responsibilities at MCHI include the direction and supervision of the company‘s government relations activities. 2. On October 19, 1998, I executed a declaration in connection with the above—referenced proceeding in which I stated that I was not aware that David Thompson of Spectrum Astro had written a letter to Kate Carr, Special Assistant to the President, until the FCC sent MCHI a copy of the letter at the same time that the other parties to this proceeding were served. I had also stated that MCHI had not solicited or encouraged Mr. Thompson to send . the letter to Ms. Carr. At the time I prepared the October 19 declaration, I had no recoilccfgign?@f having seen this letter before it was sent to MCHI by the FCC, nor did I recall that I ever asked _ Mr. Thompson to send this letter to Ms. Carr. I still have no such recollection. 3. However, I have recently seen a draft of Mr. Thompson‘s letter which indicates that I reviewed and commented on the letter. This raises questions in my mind as to the nature and extent of my involvement with this letter, and whether I may have encouraged Mr. DC_DOCS\219424.3

Thompson to use his contacts to advocate a change in policy issues such as the FCC‘s treatment of small businesses as evidenced by the FCC‘s financial qualification standards. I still have no specific recollections of this matter, however. Accordingly, I wish to amend my earlier statement to this limited extent. I declare under penalty of perjury that the foregoing is true and correct. Executed on JunE=~, 1999. Gerald B. Helman DC_DOCS\219424.3


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