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URGENT MOTION
TO REQUEST FOR COPIES
OF RELEVANT DOCUMENTS
AND
FOR LEAVE AND TIME
TO FILE VERIFIED OPPOSITION
that on May 23, 2011, it will hear the request of the Philippine Long Distance
referred to as the “JGS Group”) and that of certain other parties in Digital
appear and file their verified opposition to the request, failing which shall be
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2. According to reports, the acquisition by PLDT of JGS Group’s
by Digitel and its subsidiaries to the JGS Group which are assumed to be
and (iii) intercompany advances of P34.1 Billion made by the JGS Group and
the Honorable Commission has not provided oppositor TXTPower and the
general public with the principal documents and other records in connection
submit its opposition to the PLDT-Digitel Deal during the hearing set by the
TXTPower respectfully moves and requests that any and all records,
documents and papers in connection with the PLDT-Digitel Deal that are in
and uploaded on the Honorable Commission's official website for viewing and
public to disclose and make available all all records, documents and papers in
connection therewith.
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5. In any case, if only to provide the Honorable Commission with
its initial position regarding the PLDT-Digitel Deal, and without prejudice to
its motion and request for leave and time to submit its verified opposition, a
consumers?" dated March 29, 2011 is attached and made an integral part
netizens and consumers take on the PLDT-Digitel Deal" dated April 11, 2011
(1998)] Considering that the PLDT-Digitel Deal will have grave implications
65%, thus raising serious concerns about provisions for adequate consumer
services and welfare. Moreover, it has recently been reported that the JGS
the 2.8% stake (out of its total 12.8% stake) it will receive from PLDT
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pursuant to the PLDT-Digitel Deal. This development highlights the need to
and requests that it be granted leave and time, particularly fifteen (15) days
from May 23, 2011, or until June 7, 2011, within which to submit its verified
papers regarding the PLDT-Digitel Deal. However, they view the Honorable
consumer services and welfare. In this regard, with all due respect, it will
serve the best interests of stakeholders, mobile technology consumers and the
general public for the Honorable Commission to accept letters and/or position
papers from all interested persons and groups whether verified or not. This is
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PRAYER
given a period of fifteen (15) days from May 23, 2011, or until June 7, 2011,