20030716ITA Petition to Intervene.pdf

Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
O, Box 2720
Boise, ID 83701
[phone]
[phone] (fax)
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2003 JUL 16 AM 9: 21
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Attorneys for Idaho Telephone Association
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BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF CENTRYTEL OF
IDAHO'S TARIFF ADVICE NO. 03-06 TO
ESTABLISH RATES FOR INTRAMTA CALLS
ORIGINATED BY CERTAIN WIRELESS
CUSTOMERS.
: CASE NO,: CEN-03-
: IDAHO TELEPHONE ASSOCIATION'
: PETITION TO INTERVENE
The Idaho Telephone Association ("ITA") petitions this Commission for leave to
intervene in the above entitled proceeding pursuant to Rules 72 and 73 of the Commission
Rules of Practice and Procedure, IDAPA 31.01.01.072 and -073. In support of this Petition
IT A states as follows:
1. The ITA is an association of independently owned telephone companies providing
local exchange service and other telecommunications services within the state ofIdaho. The
IT A is charged with representing its member companies' interests before the Idaho Public
Utilities Commission and other regulatory agencies.
2. The ITA has a direct and substantial interest in these proceedings because this
Commission s decision may, directly or indirectly, affect the ITA member companies' quality or
cost of telecommunications service.
IT s PETITION TO INTERVENE
3. The ITA is unable to state its position at this stage of the proceedings, and therefore
seeks to intervene for the purpose of receiving documents, examining witnesses, and otherwise
participating as its interest may appear.
4. The ITA's representatives for the purpose of service of pleadings and other written
materials are:
Conley Ward
GIVENS PURSLEY, LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, ID 83701
[phone]
[phone] (fax)
Clay R. Sturgis
MOSS ADAMS LLP
601 W, Riverside, Suite 1800
Spokane, W A 99201-0663
[phone]
[phone] (fax)
WHEREFORE, the IT A respectfully requests that the Commission grant this Petition to
Intervene and authorize the IT A to participate in the above entitled proceedings with full rights
as a formal party.
DATED this 15th day of July, 2003.
Co leyGI N SLEY LLP
Attorneys for Idaho Telephone Association
IT A's PETITION TO INTERVENE - 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of July, 2003, I caused to be served a true and
correct copy of the foregoing by the method indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ill 83720-0074
-1L u.S. Mail - Fax - By Hand
Morgan W. Richards Jr., Esq.
Moffat Thomas Barrett Rock & Fields
Chartered
O. Box 829
Boise, ill 83701-0829
u.S. Mail - Fax - By Hand
Bill Weinman
707 13th St. SE, Suite 280
Salem, OR 97301-4036
u.S. Mail - Fax - By Hand
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Lauren Paul
IT A's PETITION TO INTERVENE - 3