IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

NORTHERN DIVISION 

FARMERS 

TELECOMMUNICATIONS 

COOPERATIVE, INC., 

 Plaintiff, 

v. 

VERIZON BUSINESS NETWORK 

SERVICES INC. and QWEST 

COMMUNICATIONS 

CORPORATION, 

 Defendants. 

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CIVIL ACTION NO. 2:06cv-00790-WC 

MOTION FOR LEAVE TO FILE AMENDED CROSS-CLAIMS

COMES NOW, Defendant, Verizon Business Network Services Inc. (“Verizon”), by and 

through its undersigned counsel, and respectfully requests this Honorable Court to grant leave, 

permitting Defendant to amend its cross-claims against Qwest Communications Corporation 

(“Qwest”). In support thereof, Verizon states as follows: 

1. Plaintiff, Farmers Telecommunications Cooperative, Inc. (“Farmers”), filed its 

complaint on September 1, 2006. On February 28, 2007, Verizon filed an answer, 

counterclaims, and cross-claims. On March 23, 2007, Farmers answered Verizon’s 

counterclaims and Qwest answered Verizon’s cross claims. 

2. This Court entered an order on March 1, 2007, which allows the parties to amend 

the pleadings before May 15, 2007. See Docket 29, § 4. 

Case 2:06-cv-00790-WC Document 43 Filed 05/08/2007 Page 1 of 3
3. On April 24, 2007, Farmers filed its First Amended Complaint for Declaratory 

Judgment. See Docket 36. Farmers filed a motion seeking leave to file its amended complaint 

on April 25, 2007. 

4. Verizon seeks leave to amend its cross-claims against Qwest in the same

document in which it files its First Amended Answer to Farmers’ First Amended Complaint. 

The proposed amendment to the cross-claims does not change the subject matter of the dispute 

and will not broaden the scope of discovery in this case. The proposed amendment merely adds 

an additional legal basis for Verizon’s cross-claims against Qwest. 

Respectfully submitted this 8th day of May 2007. 

s/ Robin H. Jones 

Bryan O. Balogh (ASB-6298-042B)

Robin H. Jones (ASB-0769-R51J) 

STARNES & ATCHISON LLP 

100 Brookwood Place 

Seventh Floor 

Post Office Box 598512 

Birmingham, Alabama 35259-8512 

205.868.6000 

205.868.6099 (fax) 

Scott H. Angstreich (pro hac vice) 

Robert A. Klinck (pro hac vice) 

KELLOGG, HUBER, HANSEN, TODD, 

 EVANS & FIGEL, P.L.L.C. 

1615 M Street, N.W., Suite 400 

Washington, D.C. 20036 

202.326.7900 

202.326.7999 (fax) 

 

 Attorneys for Defendant

Verizon Business Network Services Inc. 

 

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Case 2:06-cv-00790-WC Document 43 Filed 05/08/2007 Page 2 of 3
CERTIFICATE OF SERVICE

I hereby certify that on May 8, 2007, I electronically filed the foregoing using the

CM/ECF system, which will provide electronic service copies to the following: 

Dana H. Billingsley dana@wilkersonbryan.com, cathy@wilkersonbryan.com 

Leigh Anne Hodge lhodge@balch.com, jglover@balch.com 

Jonathan Michael Hooks jonathan@wilkersonbryan.com, 

Robin Garrett Laurie rlaurie@balch.com, dearly@balch.com 

Joseph Seawell Moore jsmoore@balch.com, dharris@balch.com 

Mark Douglas Wilkerson mark@wilkersonbryan.com, cathy@wilkersonbryan.com 

Notice will be delivered by other means to: 

Jana Eisinger 

QWest Services Corporation 

1801 California Street 

Suite 900 

Denver, CO 80202 

Patrick H. Tate 

P.O. Box 680593 

Fort Payne, AL 35968 

 

 

 s/ Robin H. Jones 

 OF COUNSEL

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Case 2:06-cv-00790-WC Document 43 Filed 05/08/2007 Page 3 of 3