20050830Petition to intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
l2m12lli:9y~hotmail. com
Attorney for Petitioner
Community Action Partnership
Association of Idaho
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION
TO DETERMINE WHETHER IT IS
REASONABLE FOR FRONTIER
COMMUNICATIONS OF IDAHO TO
PROVIDE TELECOMMUNICATIONS
SERVICE TO CUSTOMERS LOCATED IN
THE TAMARACK RESORT
CTC-05-
MATTHEW CASTRIGNO'
PETITION TO INTERVENE
COMES NOW, Matthew Castrigno and, pursuant to Rules 071-075 of the
Commission s Rules of Practice and Procedure, IDAPA 31.01.01.071-075, hereby
petitions the Commission for leave to intervene in this proceeding and to appear and
participate with full parties' rights. In support of this Petition, Mr. Castrigno states as
follows:
The address and name of the respective Intervenor is:
Matthew Castrigno
3200 N. Glen Stuart Lane
Eagle, ID. 83616
This Intervenor will be represented in this proceeding by, and pleadines and
other correspondence need on Iv be sent
Brad M. Purdy
Attorney at Law
PETITION TO INTERVENE OF MATTHEW CASTRIGNO
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: Qmpurdy~ho mail. com
Mr. Castrigno is an individual who owns real property (vacation home) located
within the Tamarack Resort located in Valley County, near Donnelley, Idaho. Mr.
Castrigno s vacation home, and the entire Tamarack Resort, is included within the
certificated area of Frontier Communications. This proceeding was spun-off Case No.
TAM-05-, in which the Commission granted Tamarack Video and Telecom, LLC, a
certificate of public convenience and necessity to provide telecommunications service to
customers within Resort boundaries. Mr. Castrigno, and two other landowners, objected
to Tamarack's application on numerous grounds and requested that Frontier be required
to provide competing service to Tamarack land owners.
The Commission ultimately granted Tamarack's application, but initiated this
proceeding for the purpose of determining whether it is reasonable to require Frontier to
provide competing service. Mr. Castrigno has a direct and substantial interest in this
proceeding for the same reasons set forth in his comments in objection to Tamarack'
application for a certificate, and in his Petition for Reconsideration. Mr. Castrigno has
legitimate concerns regarding the ability of Tamarack to adequately provide essential
reliable, telecommunications service and to do so at reasonable rates. Mr. Castrigno
involvement in this case will not unduly broaden the scope of issues of fact or law.
It is not clear if this matter will proceed to hearing. In the event it does, Mr.
Castrigno reserves his all his rights as a party, including the opportunity to submit
PETITION TO INTERVENE OF MATTHEW CASTRIGNO
comments, introduce testimony and exhibits, cross-examine other witnesses, engage in
oral argument and otherwise fully participate as a party.
WHEREFORE, Matthew Castrigno hereby requests that this Commission grant
his Petition to Intervene in this proceeding and to fully appear and participate as a party
with all the attendant rights and responsibilities.
,.,
DATED this--5V day of August, 2005.
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Iriad . Purdy c-::;7-'
PETITION TO INTERVENE OF MATTHEW CASTRIGNO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of August, 2005, I caused to be served
the foregoing PETITION TO INTERVENE OF MATTHEW CASTRIGNO on the
following, by U.S. mail, postage prepaid, in Case No. CTC- T-05-
Conley E. Ward
Givens Pursley, LLP
601 W. Bannock St.
O. Box 2720
Boise, ID. 83701-2720
Mary Hobson
Stoel Rives LLP
101 S. Capitol Blvd.
Boise, ID. 83702
Frontier Communications of Idaho
4 Triad Center, Suite 200
Salt Lake City, UT 84180
Charles Best
4400 NE 77th Ave.
Vancouver, WA 98662
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PETITION TO INTERVENE OF MATTHEW CASTRIGNO