3. FONES4ALL's Motion

FONES4ALL asserts in its motion that it will be unable to provide ULTS if the cap on the recovery of lost revenues adopted by D.00-10-028 is permitted to go into effect. Accordingly, FONES4ALL moves for a stay of the provisions of D.00-10-028 that limit the recovery of lost revenues pending consideration by the Commission of FONES4ALL's petition to modify D.00-10-028.