BEFORE THE PUBLIC UTILITIES COMMISSION FILED OF THE STATE OF 01/19/21 04:59 PM Application of A. 20-05-010 Corporation, Frontier California Inc. (U 1002 C), (Filed May 22, 2020) Citizens Telecommunications Company of California Inc. (U 1024 C), Frontier Communications of the Southwest Inc. (U 1026 C), Frontier Communications Online and Long Distance Inc. (U 7167 C), Frontier Communications of America, Inc. (U 5429 C) For Determination That Corporate Restructuring Is Exempt From or Compliant With Public Utilities Code Section 854.

MOTION OF FRONTIER COMMUNICATIONS CORPORATION, FRONTIER CALIFORNIA, INC., CITIZENS TELECOMMUNICATIONS COMPANY OF CALIFORNIA INC., FRONTIER COMMUNICATIONS OF THE SOUTHWEST INC., FRONTIER COMMUNICATIONS ONLINE AND LONG DISTANCE INC. AND FRONTIER COMMUNICATIONS OF AMERICA, INC. AND THE YUROK TRIBE FOR ORDER TO SHORTEN TIME FOR COMMENTS ON SETTLEMENT AGREEMENT

Kori Cordero Mark P. Schreiber Associate General Counsel Patrick M. Rosvall Yurok Tribe Sarah J. Banola PO BOX 1027 William F. Charley Klamath, CA 95548 Aaron P. Shapiro Tel: (707) 482-1350 COOPER, WHITE & COOPER LLP E-mail: [email protected] 201 California Street, 17th Floor San Francisco, CA 94111 Sara Clark Phone: (415) 433-1900 Shute, Mihaly & Weinberger LLP Fax: (415) 433-5530 396 Hayes Street E-mail: [email protected] San Francisco, CA 94102 Tel: (415) 552-7272 E-mail: [email protected]

Attorneys for the Yurok Tribe Attorneys for Frontier

January 19, 2021

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1 / 3 Pursuant to Rule 11.1 of the California Public Utilities Commission’s Rules of Practice and Procedure (“Rules”), Frontier Communications Corporation (“Frontier”), Frontier California Inc. (U 1002 C), Citizens Telecommunications Company of California Inc. (U 1024 C), Frontier Communications of the Southwest Inc. (U 1026 C), Frontier Communications Online and Long Distance Inc. (U 7167 C), and Frontier Communications of America, Inc. (U 5429 C) (collectively, “Frontier”) and the Yurok Tribe (collectively, the “Parties”) hereby request an order shortening time for comments on the Settlement Agreement submitted by the Parties (the “Frontier-Yurok Settlement”) through a separate, contemporaneously-filed joint motion.1 Absent shortened time, opening comments would be due on this settlement on February 18, 2021, with reply comments on March 5, 2021. See Rule 12.2 (providing 30 days for opening comments and 15 days for reply comments). The unique exigencies of this proceeding, and the critical need for Frontier to emerge from bankruptcy no later than the end of March 2021, merit an abbreviated schedule. Therefore, the Parties hereby propose that opening comments on the Frontier-Yurok Settlement, if any, be due on January 27, 2021, the same day that has been set for reply comment on the other settlements.2 Reply comments, if any, should be filed by January 29, 2021. Frontier has communicated with the parties about this proposed shortening of time for comment, and all parties either support, do not oppose, or have no position on the request. Based on these communications, Frontier understands that comments on the settlement, if there are any, would be limited and could be reasonably supplied by the Parties’ proposed dates. Good cause exists to grant this request, as it will facilitate an efficient and timely review of the Frontier-Yurok settlement along with the other two settlements submitted in this proceeding, and thereby allow the Commission to act upon the motions to accept these settlements as a final resolution of this proceeding in time for Frontier from bankruptcy on the anticipated date. The Parties have a strong interest in expediting the consideration of this settlement so that the benefits of the Restructuring and the public interest benefits of the various settlements can be realized as soon as possible. If time is shortened as requested, the schedule should allow reasonable time for the

1 See Joint Motion of Frontier Communications Corporation, Frontier California, Inc., Citizens Telecommunications Company of California Inc., Frontier Communications of the Southwest Inc., Frontier Communications Online and Long Distance Inc., Frontier Communications of America, Inc. and the Yurok Tribe for Adoption of Settlement Agreement.

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2 / 3 Commission to receive any feedback on the pending settlements by January 27th, prepare a proposed decision addressing those settlements in February, and place an item on the Commission’s agenda for adoption of a final decision no later than March 18, 2021. Based on the Commission’s schedule for 2021 voting meetings, this is the last opportunity for the Commission to issue a final decision in time to meet the current Chapter 11 emergence deadline of March 31, 2021. In this regard, Frontier notes that the Federal Communications Commission (“FCC”) has now approved the Restructuring and the necessary approvals from all remaining states are anticipated to be finalized by early February.3 This will mean that, even under a best case scenario, including the granting of this motion, the California Commission’s approval will be the last outstanding predicate to emergence. However, granting this motion will minimize the time necessary to navigate this last procedural obstacle to a realization of the benefits of the Restructuring nationwide. Prompt resolution of this proceeding is in the public interest, and the requested adjustments will not prejudice any party. All active parties have agreed to supply input, if any, on the Frontier-Yurok settlement by January 27, 2021. The Parties understand that the motion is unopposed and ask that it be expeditiously granted, as permitted by Rule 11.1(g). Executed at San Francisco, California on this 19th day of January 2021. 4 Mark P. Schreiber Patrick M. Rosvall Sarah J. Banola William F. Charley Aaron P. Shapiro COOPER, WHITE & COOPER LLP 201 California Street, 17th Floor San Francisco, CA 94111 Phone: (415) 433-1900 Fax: (415) 433-5530 E-mail: [email protected] By: /s/ Patrick M. Rosvall Patrick M. Rosvall

Attorne ys for Frontier

2 See January 5, 2021 Email Ruling at 1 (shortening time for consideration of CETF and Cal Advocates/TURN/CWA settlements to January 27, 2021). 3 All state commissions have now approved the Restructuring except for California and Connecticut, and the Connecticut approval has been set for consideration on February 3, 2021. 4 Pursuant to Commission Rule 1.8(d), counsel for Frontier is authorized to sign this Joint Motion on behalf of the Parties.

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