Federal Communications Commission FCC 14-149
Before the
Federal Communications Commission
Washington, D.C.  20554
In the Matter of
MARITIME COMMUNICATIONS/LAND
MOBILE, LLC
Participant in Auction No. 61 and Licensee of
Various Authorizations in the Wireless Radio
Services
Applicant for Modification of Various
Authorizations in the Wireless Radio Services
Applicant with ENCANA OIL AND GAS (USA), 
INC.; DUQUESNE LIGHT COMPANY, DCP
MIDSTREAM, LP; JACKSON COUNTY
RURAL MEMBERSHIP ELECTRIC
COOPERATIVE; PUGET SOUND ENERGY,
INC.; ENBRIDGE ENERGY COMPANY INC.; 
INTERSTATE POWER AND LIGHT
COMPANY; WISCONSIN POWER AND
LIGHT COMPANY; DIXIE ELECTRIC
MEMBERHIP CORPORATION, INC.;
ATLAS PIPELINE-MID CONTINENT, LLC;
AND SOUTHERN; CALIFORNIA REGIONAL 
RAIL AUTHORITY
For Commission Consent to the Assignment of
Various Authorizations in the Wireless Radio
Service
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EB Docket No. 11-71
File No. EB-09-IH-1751
FRN:  0013587779
Application File Nos.
0004030479, 0004144435
0004193028, 0004193328
0004354053, 0004309872,
0004310060, 0004314903,
0004315013, 0004430505, 
0004417199, 0004419431  
0004422320, 0004422329,
0004507921, 0004153701,  
0004526264, and 0004604962
MEMORANDUM OPINION AND ORDER
Adopted:  October 7, 2014 Released:  October 14, 2014
By the Commission:
I. INTRODUCTION
1. By this memorandum opinion and order, we dismiss the “Appeal under Rule § 1.301(a),” 
filed January 28, 2014 (as corrected), by Warren Havens (Appeal).  Havens seeks interlocutory review of 
a procedural ruling (14M-3) by Chief Administrative Law Judge Richard L. Sippel (ALJ) that rejected 
Havens’ claim of attorney-client privilege at a prehearing conference.
1
  We find that a subsequent ruling 
                                                     
1
See Order, FCC 14M-3 (Jan. 17, 2014) (14M-3).  Various parties filed oppositions or responses to Havens’ Appeal.  
See Response of Technology Law Group to Interlocutory Appeal of Order FCC 14M-3, filed February 4, 2014 (TLG 
Response); Submission of Mr. James Ming Chen to Warren Havens’ January 28, 2014 Interlocutory Appeal, filed 
February 4, 2014 (Chen Submission); Enforcement Bureau’s Opposition to Mr. Havens’ Interlocutory Appeal, filed 
February 4, 2014 (EB Opposition); Maritime’s Opposition to Havens’ January 28, 2014 Interlocutory Appeal, filed 
(continued. . .) 
Federal Communications Commission FCC 14-149
2
by the ALJ has mooted appeal of the attorney-client privilege question.
2
We also dismiss six other
interlocutory appeals that Havens has filed concerning the same proceeding.  
II. BACKGROUND
2. Proceedings below.  In this hearing proceeding, EB Docket No. 11-71 (Maritime 
Proceeding), the Commission designated issues against a company called Maritime 
Communications/Land Mobile, LLC (Maritime) to determine whether Maritime’s wireless radio licenses 
should be revoked and its related wireless radio applications should be denied.
3
  The designated issues 
include whether Maritime failed to disclose its real-parties-in-interest, whether Maritime made 
misrepresentations or lacked candor, whether Maritime committed rules violations, and whether certain of 
Maritime’s licenses automatically cancelled for failure to construct or operate.
4
  Havens is a party to the 
Maritime Proceeding.  
3. The ALJ stayed the Maritime Proceeding, with the exception of one issue, to permit the 
Commission to consider whether Maritime should be allowed to transfer its authorizations pursuant to the 
Commission’s Second Thursday doctrine.
5
  Litigation of the remaining issue, “Issue (g),” which concerns 
the question of whether some of Maritime’s licenses have automatically cancelled, has proceeded through 
the discovery phase.  
4. The matters before us arise from Maritime’s attempts to obtain summary decision on 
Issue (g) and Havens’ opposition to these attempts.  On August 14, 2013, the ALJ granted in part and 
denied in part Maritime’s May 8, 2013, Motion for Summary Decision on Issue (g).
6
  In partially denying 
the motion, the ALJ noted that Havens was appearing pro se, and that, generally, pursuant to Commission 
policy, summary decision should not in fairness be used against parties who appear pro se.
7
In response 
to Maritime’s continuing efforts to seek summary disposition, Havens subsequently, on December 2, 13, 
filed a motion asking the ALJ to reject further summary disposition of Issue (g).  In that motion, Havens 
(Continued from previous page)                                                            
February 7, 2014; Choctaw’s Opposition to Interlocutory Appeal of Warren Havens, filed February 5, 2014.  See 
also Enforcement Bureau’s Comments on the January 17, 2014 Prehearing Conference, filed January 27, 2014.  
Havens has moved to strike the opposition of Choctaw Telecommunications, LLC and Choctaw Holdings, LLC 
(collectively, Choctaw).  See Request to Strike and Comments on Choctaw’s “Opposition to Interlocutory Appeal of 
Warren Havens,” filed February 14, 2014.  Choctaw was permitted to intervene in the Maritime Proceeding for the 
limited purpose of updating the status of its application for Second Thursday relief.  See infra note 5; Order, FCC 
13M-4 (Mar. 11, 2003) at 3.  Consequently, Choctaw’s pleading is beyond the scope of its authorized participation, 
and we grant Havens’ motion to strike it.  See infra para. 15.
2
See Memorandum Opinion and Order, FCC 14M-18 (Jun. 17, 2014) (14M-18).
3
See Maritime Communications/Land Mobile, LLC, 26 FCC Rcd 6520 (2011) (HDO).
4
See HDO, 26 FCC Rcd at 6547 ¶ 62.
5
See Order, FCC 13M-6 (Mar. 31, 2013).  See also Public Notice, DA 13-569 (Mar. 28, 2013).  Under the Second 
Thursday doctrine, a bankrupt licensee, the qualifications of which are subject to a hearing proceeding, may sell its 
stations where alleged wrongdoers would not benefit from the sale and the proceeds would be used to reimburse 
innocent creditors.  See Second Thursday Corp., 22 FCC 2d 515, recon. granted on other grounds, 25 FCC 2d 112 
(1970).  Choctaw is the transferee of Maritime’s licenses specified in the proposed Second Thursday transaction.  
The Commission ultimately denied Maritime’s request for Second Thursday relief, but removed some licenses from 
hearing to consider applications to transfer them to the Southern California Regional Rail Authority for positive 
train control.  See Maritime Communications/Land Mobile, LLC, Debtor-In-Possession, FCC 14-133 (Sept. 11, 
2014).
6
See Memorandum Opinion and Order, FCC 13M-16 (Aug. 14, 2013) (13M-16).  
7
See 13M-16 at 7-9 ¶¶ 17-20.  See also Summary Decision Procedures, 34 FCC 2d 485, 488 ¶ 6 (1972) (“[A] 
motion for summary decision should not in fairness be used against parties who appear without counsel [except 
where the issues are more simple than complex and the pro se party has personal knowledge of the facts].”).
Federal Communications Commission FCC 14-149
3
indicated that “Havens[’] actions in this hearing on a pro se basis have been informed by assisting counsel 
as to procedure and substance.”
8
  On that same date, Maritime filed a further motion for summary 
disposition, in which the FCC’s Enforcement Bureau joined.
9
  On December 16, 2013, responding to that
joint motion, Havens (despite his earlier representations about “assisting counsel”) renewed his argument 
that summary decision should not be used against him because he is participating in the proceeding 
pro se.
10
5. In response to Havens’ December 16 filing, the ALJ took several actions to inquire into 
whether and to what extent Havens’ pleadings reflected the assistance of counsel, ultimately scheduling a 
prehearing conference to examine Havens’ assisting counsel regarding the nature and scope of the 
services they have provided Havens.
11
  In advance of the prehearing conference, Havens objected to any 
possible examination of assisting counsel, asserting that the ALJ’s proposal to question them as to their
services was barred because that topic is privileged.
12
At Havens’ direction, assisting counsel declined at 
the hearing to answer any of the ALJ’s questions.
13
6. In 14M-3, which memorializes and expands upon an oral ruling at the prehearing 
conference, the ALJ rejected Havens’ claims of privilege.
14
  In the Appeal, Havens asks the Commission 
to overturn 14M-3 because it requires legal counsel who assisted him to disclose information protected 
under the attorney-client privilege.
15
  
7. During the pendency of Havens’ Appeal, in a decision released June 17, 2014, the ALJ 
granted in part and denied in part Maritime and the Enforcement Bureau’s joint motion for summary 
decision.
16
  In so doing, the ALJ rejected the argument of Havens’ December 16 opposition
17
that Havens 
is entitled to lenient treatment as a pro se litigant.
18
  The ALJ reached that decision without the benefit of 
responses to the questions that Havens’ assisting counsel refused to answer at the prehearing conference
concerning the nature of their assistance to Havens.
19
                                                     
8
Havens-SkyTel First Motion Under Order 13M-19 to Reject Settlement, Proceed With the Hearing and Provide 
Additional Relevant Discovery, filed December 2, 2013, at 1 n.1. 
9
See Joint Motion of Enforcement Bureau and Maritime [Communications/Land Mobile, LLC] for Summary 
Decision on Issue G, filed December 2, 2013.
10
See Havens Opposition to Joint Motion for Enforcement Bureau & [Maritime] for Summary Decision on Issue G, 
filed December 16, 2013, at 104-05, quoting 13M-16 at 7 ¶ 18.   
11
See Order, 14M-1 (Jan. 8, 2014) (14M-1), at 2-3 ¶¶ 3-7.  Havens’ interlocutory appeal of 14M-1 is discussed infra 
at paragraphs 9 through 11.
12
See Motion for Relief regarding Order FCC 14M-1 (the “Order”), filed January 15, 2014, at 2 ¶ 2.    
13
See generally tr., Volume 8.
14
See 14M-3 at 1-2.  See also id. at 3 n.3; tr. at 8-1063-64 (bench ruling).
15
See Appeal at 2.  In the Appeal, Havens invokes “[p]rivileges,” id., that he describes as “attorney-client privilege, 
work product, and confidentiality,” id. at 4.  In 14M-3, however, the ALJ restricted his analysis to the attorney-client 
privilege, finding that Havens did not raise any other privilege “with respect to particular questions asked in the 
January 17, 2014, prehearing conference.”  14M-3 at 1 n.2.  Because we dismiss Havens’ appeal as moot, see infra 
para. 8, we need not consider or decide whether the ALJ correctly limited the scope of his analysis.
16
See 14M-18; supra note 9.
17
See supra para. 4 and note 8.
18
See 14M-18 at 12-14 ¶¶ 33-37.
19
See id. at 14 ¶ 37.  Havens has not sought interlocutory review of this aspect of the ALJ’s June 17, 2014, order.  
Federal Communications Commission FCC 14-149
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III. DISCUSSION
8. Appeal of 14M-3.  As reflected in the transcript of the prehearing conference
20
—as well 
as in several of the oppositions to Havens’ Appeal
21
—the ALJ’s purpose in seeking to question Havens’ 
assisting counsel at the prehearing conference was to obtain information that would inform the ALJ’s 
analysis of whether Havens should receive lenient treatment as a pro se litigant when opposing Maritime 
and the Enforcement Bureau’s joint motion for summary decision on Issue (g).
22
  In the June 17, 2014, 
order, however, the ALJ was able to resolve that question without recourse to further information from 
Havens’ assisting counsel.
23
  Accordingly, we find that whether the ALJ erred in overruling Havens’ 
privilege claims at the prehearing conference—which is the sole question presented in Havens’ Appeal 
that is suitable for interlocutory appeal as a matter of right under the Commission’s rules
24
—is moot.  We
therefore dismiss Havens’ Appeal.
9. Other Appeals.  In addition to challenging 14M-3, Havens has filed interlocutory appeals 
concerning other procedural rulings in the Maritime Proceeding.  Two of these, 13M-22
25
and 14M-1,
26
relate to aspects of the ALJ’s attempts to inquire into Havens’ legal assistance preliminary to 14M-3.  
Two other orders, 14M-22 and 14M-25, concern actions regarding Havens’ legal representation following 
14M-3.  We will not discuss these matters at great length, because none of the orders involved falls within 
the scope of rulings that qualify for interlocutory appeal as of right.      
10. Appeals of 13M-22 and 14M-1. Havens asserts that he may appeal both 13M-22 and 
14M-1 as a matter of right under § 1.301(a).
27
  Contrary to his assertions, however, neither 13M-22 nor 
14M-1 falls within the categories of rulings that may be appealed as of right on an interlocutory basis.
28
                                                     
20
See, e.g., tr. at 8-1040, lines 10-12 (explaining, in response to inquiries from Havens concerning the purpose of 
the ALJ’s questions:  “Why should I give you any leniency for being pro se if you have got ghost writer lawyers 
behind you cranking this stuff out?”); id. at 8-1051, lines 20-25  (“Because again, I have got this problem measuring 
the substantial participation, whether Mr. Havens is substantially participating in these pleadings as to whether he is 
entitled to [my] looking at him in a lenient fashion as opposed to an attorney.  In other words, [whether] he kind of 
gets [an] advantage.”).
21
See, e.g., TLG Response at 4 (characterizing “the issue that gives rise to this appeal” as “the propriety of 
deference to Mr. Havens as a pro se party”); Chen Submission at 4 (calling “[t]he issue of Mr. Havens’ pro se 
status . . . the only issue in question here”); EB Opposition (“The privilege issue arose because the Presiding Judge 
had sought information about whether Mr. Havens—who had asserted that he was appearing pro se and had sought 
special consideration on that basis—had in fact received the advice of counsel on issues pertinent to a pending 
motion for summary decision.” (footnote omitted)).
22
See supra note 9.
23
See 14M-18 at 14 ¶ 37.
24
See 47 C.F.R. § 1.301(a)(2).  A ruling that requires testimony or the production of documents over a claim of 
privilege is one of five classes of rulings that qualify for interlocutory appeal as a matter of right.  See infra note 28.  
Other matters raised in Havens’ appeal are outside the scope of § 1.301(a).
25
Order, FCC 13M-22 (Dec. 19, 2013) (13M-22).
26
See supra note 11.
27
See Interlocutory Appeal Under Section 1.301(a), filed January 15, 2014 (appealing 14M-1); Interlocutory Appeal 
Under Section 1.301(a), filed December 31, 2013 (as corrected) (appealing 13M-22); see also Request to Accept and 
Supplement to Interlocutory Appeal Under Section 1.301(a), filed January 7, 2014 (concerning 13M-22).  
28
The five types of rulings appealable as a matter of right are: (1) a ruling that denies or terminates a person’s right 
to participate as a party, (2) a ruling that requires testimony or the production of documents over a claim of 
privilege, (3) a ruling that denies a motion to disqualify the presiding judge, (4) a ruling that grants a settlement 
without terminating the proceeding, and (5) a ruling that removes a counsel from the hearing.  See 47 C.F.R. 
§ 1.301(a).  With respect to other rulings, a party may ask the ALJ for leave to file an interlocutory appeal upon a 
(continued. . .) 
Federal Communications Commission FCC 14-149
5
More specifically, 13M-22 addresses several procedural issues: (1) suspension of the pre-hearing 
calendar, (2) the timeliness of Havens’ filings, (3) a requirement that Havens’ assisting counsel file 
notices of appearance, (3) a request for an extension of time, (4) a motion for further discovery, (5) the 
status of allegedly undisclosed evidence, (6) a motion for declaratory ruling, and (7) a glossary
submissions by the parties.
29
  None of these issues falls within the scope of § 1.301(a), inasmuch as none 
of the ALJ’s corresponding rulings terminates the right of a party to participate in the proceeding, 
removes counsel from the hearing, or fits within any of the other specified categories of rulings that 
qualify for interlocutory review as of right.  Similarly, we do not construe 14M-1 as a ruling within the 
scope of § 1.301(a).  14M-1 is the order in which the ALJ scheduled the prehearing conference dealing 
with Havens’ assisting counsel.
30
  We do not construe an order scheduling a prehearing conference as 
falling within the scope of § 1.301(a). Because neither 13M-22 nor 14M-1 is appealable to the 
Commission as a matter of right, we dismiss Havens’ appeals of those rulings pursuant to § 1.301(a).
11. In addition to appealing 13M-22 and 14M-1 as a matter of right under § 1.301(a), 
Havens alternatively sought permission from the ALJ to file interlocutory appeals of those same orders 
pursuant to 47 C.F.R. § 1.301(b), the provision of the Commission’s rules that governs discretionary 
review of interlocutory rulings.
31
The ALJ denied Havens’ requests.
32
  On February 4, 2014, Havens filed 
an appeal of the ALJ’s ruling denying Havens’ request for discretionary leave to file an interlocutory 
appeal of 14M-1.
33
  Similarly, on March 6, 2014, Havens filed an appeal of the ALJ’s ruling denying 
Havens’ request, under 47 C.F.R. § 1.301(b), for leave to file an interlocutory appeal of 13M-22.
34
  Under 
§ 1.301(b), ALJ rulings that deny permission to file “discretionary” interlocutory appeals are final, i.e.,
nonappealable.  We therefore dismiss Havens’ February 4 and March 6 appeals.
35
12. Appeal of 14M-22.  On July 22, 2014, Havens filed an appeal under § 1.301(a) of an 
order addressing procedural dates for the completion of discovery and the commencement of the hearing 
for Issue (g).
36
  The order states: “[C]ounsel representing Mr. Havens at trial SHALL FILE AND SERVE 
a Notice of Appearance on or before July 30, 2014.”
37
13. 14M-22 does not fall within the categories of rulings that would be appealable as a 
matter of right, which categories include rulings that “den[y] or terminate[] the right of any person to 
(Continued from previous page)                                                            
showing that the appeal presents a new or novel question of law or policy and that the ruling is such that error would 
likely require remand should the appeal be deferred and raised as an exception.  See id. § 1.301(b).
29
See 13M-22 at 2-8 ¶¶ 2-17.
30
See 14M-1 at 1-2 ¶ 1; see also supra paragraph 5.
31
See Request Under Section 1.301(b) , filed January 16, 2014 (errata copy) (requesting permission to appeal 14M-
1); Request [to appeal] under Section 1.301(b), filed December 27, 2013, and similar pleadings filed December 30, 
2013, and January 7, 2014 (requesting permission to appeal 13M-22).
32
See Order, FCC 14M-6 (Jan. 30, 2014); Order, 14M-7 (Feb. 26, 2014).
33
See Order, 14M-6 (Jan. 30, 2014); Interlocutory Appeal Under § 1.301(a), filed February 4, 2014 (February 4 
Appeal); Enforcement Bureau’s Opposition to Mr. Havens’ Interlocutory Appeal, filed February 11, 2014. 
34
Order, FCC 14M-7 (Feb. 26, 2014); Interlocutory Appeal Under § 1.301(a), filed March 7, 2014 (as corrected). 
35
  Havens states that, in addition the ALJ’s rulings denying leave to file interlocutory appeals of 13M-22 and 14M-
1, the February 4 and March 6 appeals cover two other orders by the ALJ: Order, FCC 14M-4 (Jan. 27, 2014), and 
Order, FCC 14M-5 (Jan. 28, 2014).  See February 4 Appeal at 1.  Those orders involve the time for filing an appeal 
of 14M-3 and other miscellaneous matters.  They do not qualify for interlocutory review as of right.  
36
See Order, FCC 14M-22 (Jul. 15, 2014) (14M-22), at 3; Appeal Under § 1.301(a) Regarding and Comments on 
FCC 14M-22, filed July 22, 2014 (Havens 14M-22 Appeal).
37
14M-22 at 3 (emphasis omitted). 
Federal Communications Commission FCC 14-149
6
participate as a party to a hearing proceeding,”
38
or that “remove counsel from [a] hearing.”
39
  Contrary to 
Havens’ assertion, we do not read 14M-22 as prohibiting Havens from representing himself, or as
prospectively terminating his participation in the Maritime Proceeding if he attempts to represent 
himself.
40
  During the course of the Maritime Proceeding, Havens has indicated on at least one occasion 
that he “intend[s] to have, but [has] not yet fully secured, legal counsel for the hearing.”
41
  We understand 
14M-22 to require any counsel whom Havens may wish to represent him at the hearing to file a notice of 
appearance on or before July 30, 2014.  We do not construe the imposition of that deadline as a 
“preemptive ‘ruling removing counsel,’” as Havens has characterized it,
42
nor as a ruling preventing 
Havens from participating as a party in the Maritime Proceeding.  Because 14M-22 thus does not 
implicate § 1.301(a), it is not appealable as a matter of right, and we dismiss Havens’ interlocutory 
appeal.
14. Appeal of 14M-25. Finally, Havens appeals an order in which the ALJ directed Havens 
and an attorney, James A. Stenger (Stenger) of the firm of Chadbourne & Parke, LLP, to file prehearing 
submissions jointly and required them to coordinate questioning witnesses and objections at the hearing.
43
  
Although no attorney has filed a notice of appearance on behalf of Havens, on July 29, 2014, Stenger 
filed a notice of appearance on behalf of two of Havens’ companies, Environmental LLC and Verde 
Systems LLC.
44
  We find that the order in question, 14M-25, which merely imposes conditions on how 
Havens, as a party, must conduct himself, does not terminate his party status.  It therefore does not 
“effectively” deny Havens’ right to participate as a party.
45
We dismiss his interlocutory appeal, 
IV. ORDERING CLAUSES  
15. Accordingly, IT IS ORDERED that the Appeal under Rule § 1.301(a), filed January 28, 
2014, by Warren Havens IS DISMISSED; the Interlocutory Appeal under Rule § 1.301(a), filed March 6, 
2014, by Warren Havens IS DISMISSED; the Interlocutory Appeal under Rule § 1.301(a), filed February 
4, 2014, by Warren Havens IS DISMISSED; the Appeal under Rule § 1.301(a), filed January 15, 2014, by 
Warren Havens IS DISMISSED; the Interlocutory Appeal Under Section 1.301(a), filed December 30, 
2013, by Warren Havens, and the Request to Accept and Supplement to Interlocutory Appeal Under 
Section 1.301(a), filed January 7, 2014, by Warren Havens ARE DISMISSED; the Appeal Under 
§ 1.301(a) Regarding and Comments on FCC 14M-22, filed July 22, 2014, by Warren Havens IS 
DISMISSED; and the Request Under § 1.301(a), filed August 18, 2014, by Warren Havens IS 
DISMISSED.
                                                     
38
47 C.F.R. § 1.301(a)(1).
39
Id. § 1.301(a)(5).
40
The Commission has recognized an individual’s right to appear pro se.  See Black Television Workshop of Los 
Angeles, Inc., 7 FCC Rcd 6868, 6870 ¶ 7 (1992) (characterizing “the right to self-representation [as] a right of high-
standing”).  In the Maritime Proceeding, although the ALJ has (legitimately) determined that Havens may not 
represent corporate parties with which Havens is affiliated, the ALJ has permitted Havens to represent himself.  See 
Maritime Communications/Land Mobile, LLC, 28 FCC Rcd 11596, 11599 ¶¶ 9-11 (2013).
41
14M-18 at 12 ¶ 31 n.101, quoting Proposed Schedule from Warren Havens, filed August 27, 2013, at 3 ¶ 4.
42
Havens 14M-22 Appeal at 2.
43
See Order, FCC 14M-25 (Aug. 11, 29014) (14M-25) at 3.  
44
See Notice of Appearance, filed July 29, 2014, by James A. Stenger, Chadbourne & Parke, LLP.  In a pleading 
filed the same day (and in some subsequent pleadings), Stenger stated that Havens (acting pro se) agreed with the 
content of the pleading and set forth Havens’ position on the merits.  See, e.g., Response to Joint Request for 
Prehearing Conference, filed July 29, 2014, at 2, n.1.
45
See Request Under § 1.301(a), filed August 18, 2014, by Warren Havens.  See also Enforcement Bureau’s 
Opposition to Mr. Havens’ Interlocutory Appeal, filed August 21, 2014; E-mail from Warren Havens to Pamela 
Kane et al. (Aug. 21, 2014).
Federal Communications Commission FCC 14-149
7
16. IT IS FURTHER ORDERED that the Request to Strike and Comments on Choctaw’s 
“Opposition to Interlocutory Appeal of Warren Havens,” filed February 12, 2014, by Warren Havens IS 
GRANTED AND Choctaw’s Opposition to Interlocutory Appeal of Warren Havens, filed February 5, 
2014, IS STRICKEN.
FEDERAL COMMUNICATIONS COMMISSION
Marlene H. Dortch
Secretary