20230728Motion to Set Supplemental Comment Deadline.pdf

STAFF’S MOTION TO SET SUPPLEMENTAL COMMENT DEADLINES - 1
CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8026

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714

Attorney for the Commission Staff

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF NOTICE BY
MILLENNIUM NETWORKS, LLC TO THE
COMMISSION OF THE ASSETS
ACQUISITION OF CTC TELECOM, INC.
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CASE NOS. CTL-T-23-03
MNL-T-23-01

STAFF’S MOTION TO SET
SUPPLEMENTAL COMMENT
DEADLINES

STAFF OF the Idaho Public Utilities Commission (“Staff”), by and through its Attorney
of record, Claire Sharp, Deputy Attorney General, respectfully requests the Commission establish
supplemental public comment deadlines and vacate the reply comment deadlines established for
Millennium Networks, LLC (“Millennium”) and CTC Telecom, Inc., (“CTC”) (collectively
“Companies”) to reply and set a new reply deadline. This motion is based on the following:
1. Commission Order No. 35852 established a July 27, 2023, deadline for public
comments and August 3, 2023 deadline for the Companies’ reply. Staff submitted
requests for information of both Companies following the Commission’s Order. The
Companies independently reached out to Staff’s Counsel and asked for additional time
to respond to Staff’s requests for information. In addition, CTC expressed concerns
about the relevance of information requested and wished to discuss those concerns with
Staff. Staff is meeting with the Companies on July 31, 2023, to resolve these issues.
RECEIVED
Friday, July 28, 2023 11:46:25 AM
IDAHO PUBLIC
UTILITIES COMMISSION
STAFF’S MOTION TO SET SUPPLEMENTAL COMMENT DEADLINES - 2
2. On July 27, 2023, Staff filed comments reflecting its position based on the information
it had reviewed, but not reflective of the information it would like to review to develop
its full position. Staff considers these preliminary comments which it would like to later
supplement.
3. Because Staff believes that resolving the discovery issues are necessary to the
proceedings and will facilitate an accurate and complete record for the Commission to
consider, Staff’s Counsel conferred with the Companies and proposed establishing
supplemental public comment and reply deadlines.
4. Staff proposes that the Commission issue an order establishing supplemental public
comment and reply deadlines to allow the Parties to fully respond to and review
discovery. Staff believes this will help create a robust record for the Commission to
make its decision upon.
5. Therefore, Staff respectfully asks the Commission issue an order consistent with this
request.

Respectfully submitted this 28th day of July 2023.

________________________________
Claire Sharp
Deputy Attorney General

STAFF’S MOTION TO SET SUPPLEMENTAL COMMENT DEADLINES - 3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 28th day of July 2023, I served the foregoing
STAFF’S MOTION TO SET SUPPLEMENTAL COMMENT DEADLINES, in Case Nos.
CTL-T-23-03 and MNL-T-23-01 , via Electronic Mail to the following:

Cynthia A. Melillo
Cynthia A. Melillo, PLLC
[e-mail]
Elizabeth A. Koeckeritz
Givens Pursley LLP
[e-mail]

______________________________
Keri J. Hawker
Legal Administrative Assistant

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