Smith v. Qwest Communications Company, LLC et al

Filing 12

Certification of Interested Entities or Persons filed by Level 3 Communications, LLC, Qwest Communications Company, LLC, Sprint Communications Company L.P., Wiltel Communications, LLC identifying Corporate Parent Level 3 Financing Inc., Corporate Parent Level 3 Communications, Inc., Other Affiliate Level 3 Communications, LLC for Wiltel Communications, LLC; Corporate Parent Quest Communications International, Inc., Corporate Parent CenturyLink, Inc., Other Affiliate Qwest Services Corporation for Qwest Communications Company, LLC; Corporate Parent Sprint Nextel Corporation for Sprint Communications Company L.P.; Corporate Parent Level 3 Financing Inc., Corporate Parent Level 3 Communications, Inc. for Level 3 Communications, LLC. (Newland, Molly) (Filed on 10/11/2011)

1 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
2
Including Professional Corporations
JAMES J. MITTERMILLER, Cal. Bar No. 85177
3 [e-mail]
501 West Broadway, 19th Floor
4 San Diego, CA 92101
Telephone:
619-338-6500
5 Facsimile:
619-234-3815
6 SHEPPARD, MULLIN, RICHTER & HAMPTON LLP
A Limited Liability Partnership
7
Including Professional Corporations
MOLLY R. NEWLAND, Cal. Bar No. 244928
8 [e-mail]
Four Embarcadero Center, 17th Floor
9 San Francisco, California 94111
Telephone:
415-434-9100
415-434-3947
10 Facsimile:
11 Attorneys for Defendants
QWEST COMMUNICATIONS COMPANY, LLC;
12 SPRINT COMMUNICATIONS COMPANY L.P.;
LEVEL 3 COMMUNICATIONS, LLC; and
13 WILTEL COMMUNICATIONS, LLC
14
15

UNITED STATES DISTRICT COURT

16

NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

17
18 TODD SMITH, individually and as
representative of a class of persons similarly
19 situated,
20
21

Case No. CV-11-02599-TEH
DEFENDANTS' CERTIFICATION OF
INTERESTED ENTITIES OR PERSONS

Plaintiff,
Courtroom: 12
Judge: Hon. Thelton E. Henderson

v.

22 QWEST COMMUNICATIONS COMPANY,
23 LLC; SPRINT COMMUNICATIONS
COMPANY, L.P.; LEVEL 3
24 COMMUNICATIONS, LLC; and WILTEL
COMMUNICATIONS, LLC,
25
Defendants.
26

[Complaint Filed: May 31, 2011]

27
28
W02-WEST:5MON1\404042793.1

CV-11-02599-TEH

DEFENDANTS' CERTIFICATION OF INTERESTED ENTITIES OR PERSONS

1

Defendants Qwest Communications Company, LLC, Sprint Communications

2 Company L.P., Level 3 Communications, LLC, and Wiltel Communications, LLC (collectively
3 "defendants") submit this certification of interested entities or persons, pursuant to Fed. R. of Civ.
4 Proc. 7.1 and Northern District of California Civ. L.R. 3-16.
5
6

Pursuant to Civil L.R. 3-16, the undersigned certifies for defendants that the

7 following listed persons, associations of persons, firms, partnerships, corporations (including
8 parent corporations) or other entities (i) have a financial interest in the subject matter in
9 controversy or in a party to the proceeding, or (ii) have a non-financial interest in that subject
10 matter or in a party that could be substantially affected by the outcome of this proceeding:
11
12

Defendant Qwest Communications Company, LLC states that: (1) it is a single

13 member limited liability company and its sole member is Qwest Services Corporation, (2) Qwest
14 Services Corporation is a wholly owned subsidiary of Qwest Communication International, Inc.
15 which is in turn a wholly owned subsidiary of CenturyLink, Inc., (3) CenturyLink, Inc. is a
16 publicly traded company, and (4) no publicly traded company has reported owning 10% or more
17 of CenturyLink, Inc.’s outstanding stock.
18
19

Sprint Nextel Corporation is a publicly traded corporation. It indirectly owns

20 defendant Sprint Communications Company L.P. and no publicly traded company has reported
21 owning 10% or more of Sprint Nextel Corporation’s stock.
22
23

Defendant Level 3 Communications, LLC states that: (1) it is a single-member

24 limited liability company, and its sole member is Level 3 Financing, Inc., (2) Level 3 Financing,
25 Inc. is a Delaware corporation and a wholly owned subsidiary of Level 3 Communications, Inc.,
26 and (3) Level 3 Communications, Inc. is a publicly traded Delaware corporation, and (4) no
27 publicly traded company has reported owning 10% or more of Level 3 Communications, Inc.’s
28 outstanding stock.
-1W02-WEST:5MON1\404042793.1

CV-11-02599-TEH

DEFENDANTS' CERTIFICATION OF INTERESTED ENTITIES OR PERSONS

1

Defendant WilTel Communications, LLC is a single-member, limited liability

2 company. WilTel Communications, LLC’s only member is Level 3 Communications, LLC.
3 Level 3 Communications, LLC’s is also a single-member, limited liability company and its only
4 member is Level 3 Financing, Inc., which is a Delaware corporation and a wholly owned
5 subsidiary of Level 3 Communications, Inc. Level 3 Communications, Inc. is a publicly-traded
6 Delaware corporation. No publicly held company owns 10% or more of Level 3
7 Communications, Inc.’s stock.
8
9
10

Dated: October 11, 2011
SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

11
12

By

/s/ Molly R. Newland
MOLLY R. NEWLAND

13

Attorneys for Defendants
QWEST COMMUNICATIONS COMPANY, LLC;
SPRINT COMMUNICATIONS COMPANY L.P.;
LEVEL 3 COMMUNICATIONS, LLC; and WILTEL
COMMUNICATIONS, LLC

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-2W02-WEST:5MON1\404042793.1

CV-11-02599-TEH

DEFENDANTS' CERTIFICATION OF INTERESTED ENTITIES OR PERSONS