20040315Application.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTllJTIES COMMISSION
PO BOX 83720
BOISE, ID 83720-0074
IDAHO BAR NO. 5470
Te1e: [phone]
FAX: [phone]
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Attorney for the Staff of the Idaho Public Utilities Commission
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE STAFF'S PETITION
TO INITIATE A COMMISSION INVESTIGATION
TO DETERMINE IF OCMC, INc. VIOLATED
THE TERMS OF ITS PRICE LIST AND THE
COMMISSION'S OPERATOR SERVICES AND
PAY TELEPHONE RULE 104.04.
CASE NO. GNR- T -04-
STAFF'S PETITION TO
INITIATE AN
INVESTIGATION
COMES NOW the Staff of the Idaho Public Utilities Commission, pursuant to Idaho
Code ~~ 62-616 and 62-620, and recommends that the Commission initiate an investigation to
resolve subscriber complaints, determine if OCMC is providing service in compliance with its
Price List and to decide ifOCMC, Inc. has violated the Commission s Operator Services and Pay
Telephone Rules, IDAPA 31.51.01 et. seq. Staff alleges that OCMC, Inc., an operator services
provider ("OSP"), operating in the State of Idaho as itself or under the assumed business names
of OPTIC OM, Inc., One Call Communications, Inc., AdvantTel, LiveTel, SuperTel, RegionTel
or 1-800-MAX-SA VE (hereinafter "OCMC") has violated the Commission s Operator Services
and Pay Telephone Rule 104.04 and the terms of its own Price List between the dates of March
, 2002 until July 29, 2003. In particular, OCMC failed to provide the opportunity for
customers to receive information about call charges on connected, intrastate collect calls.
JURISDICTION
1. Idaho Code 9 62-603 of the Telecommunications Act of 1988 provides that
(tJhe Commission shall administer these statutes with respect to telecommunications rates and
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
services in accordance with (the policies of the 1988 Act) and applicable federal law.Idaho
Code 9 62-604 provides that any telephone corporation that "did not, on January 1 , 1988, hold a
certificate of public convenience and necessity issued by the commission and, which does not
provide basic local exchange service, shall, on and after the effective date of this act, be subject
to the provisions of (Chapter 6, Title 62.
2. OCMC's Price List provides for the "description, rules, regulations, rates and
charges applicable to interexchange carrier telecommunications services and operator assisted
services offered by OCMC, Inc. . . within the State of Idaho.Price List at Original Sheets No.
6 and 12. OCMC's Price List conclusively demonstrates that the Company is a telephone
corporation and the operator-assisted services it provides in Idaho are telecommunications
services. Idaho Code 9 62-603(13) and (14). See also Title 62 Telephone Corporation Rules
IDAPA 31.42.01.001. Accordingly, the Company is subject to the Commission s regulatory
authority contained in Title 62.
3. The Commission also has the authority to implement the Federal
Telecommunications Act of 1996 and to create rules to carry out duties authorized by it. Idaho
Code 9 62-615.See also Idaho Code 9 62-602(4).In addition, in enacting the Idaho
Telecommunication Act of 1988 the Legislature intended "to protect and maintain high-quality
universal telecommunications at just and reasonable rates by a balanced program of regulation
and competition.Idaho Code 9 62-602(1).
4. Idaho Code 9 62-620 provides the Commission with authority to determine
whether its rules have been violated.
5. As stated previously, Staff has received complaints from consumers and obtained
evidence through its own investigation that shows OCMC has violated the requirements of Rule
104.04.
6. Idaho Code 9 62-616 vests the Commission with the "authority to investigate and
resolve complaints made by subscribers to (Title 62) services which are subject to the provisions
of this chapter (which concern) whether prices and conditions of service are in conformance with
filed tariffs or prices lists(.
I On May 7, 2002, the Commission received a letter from counsel for the Company stating that One Call
Communications, Inc., a registered Title 62 Company, was changing its name to OCMC, Inc.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
7. OCMC had its price list on file with the Commission between March 15 , 2002
and July 29 2003. One Call Communications Price List (effective March 23 , 1992). In Section
III of this Price List - "Special Conditions Governing Operator Services" the Company stated
that
, "
Rates will be provided on request." !d. at First Revised Sheet No. 41. Through Staffs
investigation and the complaints it received from consumers, it is clear that OCMC has not
provided its services in Idaho in compliance with this provision of its Price List.
8. Based on the foregoing, the Commission has jurisdiction to investigate the above
matters.
II.
STATEMENT OF FACTS
9. The Defendant/Respondent is OCMC, Inc. OCMC is incorporated in the State of
Indiana and has a Certificate of Authority to transact business as a foreign corporation within the
State of Idaho. OCMC provides intrastate, intraLATA interexchange telecommunications
services and operator assisted services in Idaho.OCMC Price List Original Sheet No.
(effective July 21 , 2003). As a Title 62 Company, OCMC must file its price lists with the
Commission and abide by the Operator Services and Pay Telephone Rules.
10. In 1988 , near implementation of the Idaho Telecommunications Act of 1988, the
Commission received several inquiries from alternate operator service ("AOS") providers
regarding the status of regulatory oversight for these telecommunications providers. 3 Order No.
21855, (Case No. GNR-88-3). In addition, the Commission had received complaints from
consumers concerning AOS provider charges. Id. at 2. These consumers alleged being unaware
that their call was being processed by the AOS rather than by the company they thought they
were using. Id. The Commission noted the Federal Communications Commission ("FCC") and
2 The Commission s Operator Services and Pay Telephone Rules derIDes Operator and Directory Assistance
Services as:
(A )ny telecommunications services that include, as a component, any automatic or live assistance
to a telephone caller to arrange for billing or completion, or both, of a telephone call. They
include, but are not limited to, intercept, call completion and assistance, and directory assistance
services, whether local, MTS, or both.
IDAPA 31.51.01.005.05. See a/so IDAPA 31.51.01.005.06 (defmition of aSP).
3 At the time of this rulemaking the Bell Companies were largely providing these services until new entities began
competing for this segement of the market. They were defined as Alternate Operator Services Providers. Today
they are simply known as asPs.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
several states had issued warnings to telephone customers regarding the practices and rates of
AOS providers as they had received a surge in complaints regarding these companies. Id.
11. In response to these issues the Commission, pursuant to Idaho Code 99 61-503
and 61-507, found the public safety and convenience required that the performance of AOS
within Idaho be governed by certain proposed rules. Id. Among the proposed rules was the
requirement that
, "
(aJll operator assisted calls must be preceded by a disclosure of the name of
the Company handling the call and the charge for making the connection " and that "(tJhe AOS
provider or its agent is responsible for conformance with all rules and regulations that apply to
the provision of this service." Order No. 21855 at p. 4.
12. After conducting a rulemaking proceeding, the Commission issued General Order
Nos. 178 and 178A that enacted these rules in November 1988. These rules governed the
provIsIOn of AOS in Idaho. Specifically, at that time, Rule 9.4 of the Commission
Interconnection Rules for AOS providers required:
(aJll calls routed to an AOS provider must be preceded by disclosure of the
AOS company s name prior to completing the connection. The notification
must clearly identify the AOS provider. Upon the caller s request, the
company handling the all must also quote the charge for making the
connection and all other related operator-service charges.
Appendix to General Order No. 178A at 3. The Commission ordered AOS providers to not
conduct intrastate business in Idaho except in conformance with these rules. General Order No.
178A.
13. In 1990, Congress, responding to widespread consumer dissatisfaction over high
charges and certain practices of many OSPs arising from calls made from payphones, enacted the
Telephone Operator Consumer Services Improvement Act of 1990 (TOCSIA), codified at 47
C. 9 226. Under TOCSIA and rules enacted at its direction, asPs were required to "brand"
calls, allow consumers to terminate calls without incurring a charge before connection, and to
disclose immediately to the consumer certain information regarding rates and charges.4 47
R. ~ 64.703(a) (1991).Section 64.703(3)(i) (1991) required the OSP to "disclose
immediately to the consumer, upon request and at no charge to the consumer - (i) A quotation of
its rates or charges for the call.
4 "Brand" is a term used for an ~sp identifying itself to a caller.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
14. On July 30, 1991 , the Commission issued General Order No. 181A that adopted
amendments to its Operator Services Rules.s These new rules generally adopted the wording of
the FCC's TOCSIA rules in order to minimize instances of dual regulatory schemes. In the
Commission s new Rule 9.4iii(A) OSPs were required to:
(dJisclose immediately to the telephone caller, upon request and at no charge
to the telephone caller: (A) a quote of the total rates and charges (including
surcharges) to be billed by OSPs and MTS companies for the call.
15. In 1996 Congress enacted the Telecommunications Act of 1996 fundamentally
changing telecommunication regulation by erecting a "pro competitive deregulatory national
framework designed to accelerate rapid private sector deployment of advanced
telecommunications and information technologies and services to all Americans by opening all
markets to competition.S. Conf. Rep. No. 104-230, 104th Cong., 2d Sess. 1 (1996). Included
in the Act was 47 US.C. 9 276 that advanced two goals of promoting competition among
payphone service providers and promoting the widespread deployment of payphone services to
the benefit of the general public." 47 US.c. 9 276(b)(1). In the proceeding to implement the
goals of this provision the FCC stated that
for purposes of ensuring fair compensation through a competitive
marketplace, the states should remove only those regulations that affect
payphone competition; the states remain free at all times to impose
regulations, on a competitively neutral basis, to provide consumers with
information and price disclosure.
In the Matter of the Implementation of the Pay Telephone Reclassification and Compensation
Provisions of the Telecommunications Act of 1996 Notice of Proposed Rulemaking, CC Docket
96-128 , DCC 96-254 at 'iI'iI16 , 49 59 and 60 (1996).
16. On June 6, 1996, the FCC released the OSP Reform Notice. Billed Party
Preference for InterLATA 0 + Calls, CC Docket No. 92-, Second Further Notice of Proposed
Rulemaking, 11 FCC Rcd 7274 (1996). In the case the FCC sought comment on whether
consistent with the requirements of the 1996 Act, it should require all OSPs to disclose their rates
on all 0 + calls.
5 On August 17, 1990, the Commission issued Order No. 23278, in Case No. 31.D-89-1 establishing a proceeding
to amend its Operator Services Rules.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
17. In 1998 the FCC issued its decision regarding the above matter.Second Report
and Order and Order on Reconsideration, In the Matter of Billed Party Preference for
InterLATA 0+ Calls CC Docket No. 92-, FCC 98-, 13 F.c.c.R. 6122, 13 FCC Rcd. 6122
(1998). In it the FCC added language to 47 c.F.R. 9 64.703 requiring OSPs, like OCMC, to
provide price disclosures on interstate calls orally to the away-fTom home caller to ensure that
consumers receive sufficient information about the rates they will pay for operator services at
public payphones and other locations. This Rule, in pertinent part requires OSPs to:
3) Disclose immediately to the consumer, upon request and at no charge to
the consumer--(i) A quotation of its rates or charges for the call; . . . .
(4) Disclose, audibly and distinctly to the consumer, at no charge and before
connecting any interstate, domestic, interexchange non-access code operator
service call, how to obtain the total cost of the call, including any aggregator
surcharge, or the maximum possible total cost of the call, including any
aggregator surcharge, before providing further oral advice to the consumer on
how to proceed to make the call. The oral disclosure required in this
subsection shall instruct consumers that they may obtain applicable rate and
surcharge quotations either, at the option of the provider of operator services
by dialing no more than two digits or by remaining on the line.
47 C.R. 64.703(a)(3) and (4).
18. In refining and clarifying the requirements of 47 C.R. 9 64.703 the FCC ruled
that the "consumer" for the purposes of collect calls meant the caller and the called party and that
rate disclosures had to be made available to both. In the Matter of Billed Party Preference for
InterLATA 0+ Calls, Second Order on Reconsideration CC Docket No. 92-, FCC 01-355, 16
FCC Rcd. 22 314 (2001).
6 In this decision the FCC noted that:
Consumer education initiatives by the industry, government, and the media appear to have
helped produce a favorable downward trend over recent years in the number of complaints
received by the Commission about high ~SP rates. Nevertheless, more than five years after
enactment of TOCSIA, the high rates of many asPs and surcharges imposed by aggregators
continue to be a concern. In 1995, the second largest category of complaints processed by
the Commission s Common Carrier Bureau consisted of complaints directed against asPs
and the vast majority of these concerned rates and charges that consumers thought were
excessive. In 1996; the Commission processed 4,132 written complaints about the level of
interstate rates and services of asPs. Accordingly. we examine in the next sections what
additional steps we can and should take to foster greater competition by asPs.
13 F.R. 6122 at ~ 9 (emphasis added).
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
19. The Commission s Operator Services and Pay Telephone Rules contain the
requirements OSPs must abide by in Idaho.
20. Rule 104., enacted on March 15, 2002, requires OSPs like OCMC to:
Disclose, audibly and distinctly to the consumer (caller for non-collect calls,
called party for collect calls), at no charge, and before connecting any
instrastate operator service call, how to obtain the total cost of the call,
including any aggregator surcharge, or the maximum possible total cost of the
call, including any aggregator surcharge, before providing further advice to
the consumer on how to proceed to make the call.The oral disclosure
required in Rule 104.04 shall instruct consumers that they may obtain
applicable rate and surcharge quotations either, at the option of the provider
of operator services, by dialing no more than (2) digits or by remaining on the
line.
IDAPA 31.51.01.104.04 (emphasis added).
21. Rule 104.04 was created through a rulemaking to make additions and changes to
the Commission s Operator Services and Pay Telephone Rules to recognize changes in federal
law particularly in the area of rate disclosure to consumers/customers. See Notice of Proposed
Rulemaking, Case No. 31-5101-0101 ("The proposed substantive changes to these Rules are
made so that the Rules are consistent with recent changes in federal law. See generally, In the
Matter of Implementation of the Pay Telephone Reclassification and Compensation Provisions of
the Telecommunications Act of 1996, CC Docket No. 96-128, Order No. 96-388 (September 20
1996))." These changes are consistent with the federal Telecommunications Act of 1996, The
Telephone Operator Consumer Improvement Act of 1990 and FCC Rules. See 47 u.S.c.9~ 276
253 and 226; 47 C.R. ~9 64.703(a)(3)(i) and (4) and 64.708(f). OCMC was an interested party
in the rulemaking before the Commission as the notices demonstrate. Notice of Public Workshop
and Negotiated Rulemaking, Order No. 28746, Service List. See also Notice of Proposed
Rulemaking Service List Case No. 31- 5101-0101.
22. After its enactment of Rule 104.04 OCMC did not request an exemption from the
application of its requirements for its services between March 15 2002 and July 29 2003.
23. On June 24, 2003 , Staff received a complaint from a consumer about OCMC'
conduct7 The consumer alleged placing a collect call to his home number in Boise, on May 29
7 In addition to the consumer complaint discussed above Staff received consumer complaints regarding OCMC'
failure to provide the opportunity to receive information about rates. Staff alleges that some of these complaints are
still unresolved. In addition, Staff has received numerous complaints regarding OCMC's rates.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
2003 , from a payphone located at the Costco Warehouse Store, 2051 S. Cole Road.8 The
consumer complained the charges for the call were excessive ($19.21 for four minutes) and the
called party was not given the opportunity to obtain information about call charges.
24. On June 27, 2003 , Staff attempted to verify the consumer s complaint by placing
a collect call from the same phone at Costco to Staff s office. Staff found that the called party on
the call was also not provided the audible notice required by Rule 104.04 about how to obtain
information about call charges. In addition, the caller on this call was not provided the
opportunity upon request to obtain information about call charges in conformance with Rule
104.03.
25. On July 3 , 2003, Staff sent correspondence to OCMC requesting that the
Company:
Provide evidence that this phone, number 208-321-9602, did provide the
customer with the required audible notice of an opportunity to obtain the
charges for the call or present plan, including a timeline, for ensuring that all
payphones in Idaho that are provided operator services by Opticom or any
other divisions of OCMC, Inc. do provide such notices.
Staff further requested that OCMC eliminate the charges for the call placed by the complaining
customer.
26. On July 16, 2003 , OCMC responded stating:
The caning party waiS auviiS~u of how io obtain a rai~ 4.uoi~. In auuiiion, ih~
called party on automated collect calls is now being instructed that they may
obtain call charges. Oral disclosure to the called party on live collect calls is
not currently in place, but should be implemented by July 31, 2003.
OCMC Letter filed July 17, 2003 (emphasis added).The Company also stated that the
complaining consumer was given a 100% credit against the charges incurred.
27. Based on the Company s response, Staff advised the Company by Letter, on
August 18, 2003 , that OCMC appeared to have violated Rule 104.04 of the Commission
Operator Services and Pay Telephone Rules. Staff stated that because OCMC's rates are
significantly higher than other OSPs, it is possible that many consumers who used its services
8 The phone at the Costco Warehouse is specifically identified by its number, (208)-321-9602.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
and were not provided the required rate disclosure would have decided to not have the collect
call connected.
28. On September 19, 2003 , Staff sent an additional letter to OCMC requesting that it
provide: 1) the dates when it began providing the called party on fully automated collect calls
and calls processed by a live operator the opportunity to obtain call charges; and 2) starting from
March 15 , 2002, the total number of intrastate collect calls OCMC processed in Idaho broken
down into two categories, those handled as automated calls as well as those handled via live
operators.
29. OCMC responded on October 2, 2003 and admitted that until the end of July
2003, it did not comply with the requirements of Rule 104.04.9 Specifically, OCMC stated it did
not begin providing the called party the opportunity to obtain information about call charges on
automated collect calls until sometime between July 3 and 16, 2003. The Company also stated it
did not provide the caller or the called party the opportunity to obtain information about call
charges through a live operator until July 29, 2003. The Company also disclosed that between
March 14, 2002 and July 31 , 2003 it processed 9 021 Idaho intrastate collect calls that were
handled by its automated system and 3 872 Idaho intrastate collect calls that were handled by
live operators.
30. Based on the foregoing call data Staff alleges that OCMC has violated Rule
104.04 of the Commission s Operator Services and Pay Telephone Rules since its effective date
on March 15, 2002 by failing to provide the required disclosures for 12 893 local collect phone
calls.
31. Staff alleges this is not the first time OCMC has possibly violated the
Commission s Operator Service and Pay Telephone Rules. In January 1995 , the Commission
approved a Consent Agreement between the Commission Staff and One Call Communications
9 It should be noted that on December 11, 2003 , the FCC adopted a Consent Decree terminating an investigation
into possible violations by OCMC, Inc. of Section 225 of the Communications Act of 1934, as amended, and the
FCC Rules governing asPs. Specifically, the Decree resolved an investigation that had found that OCMC had
violated the FCC's Rules regarding asPs by failing to brand at the origination point of operator service calls
placed via toll-fee access codes; failing to brand at the termination point on certain access code calls; and failing
to provide rate information at the termination point of these access code calls. In the Matter of aCMe, Inc. dba
One Call Communications, Inc. dba OPTICOM 2003 WL 22928442 (F.c. 2003). To resolve this investigation
OCMC agreed: to make a $500 000 contribution to the United States Treasury; and to engage in certain practices
to ensure future compliance with the FCC's Rules.
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
Inc., OCMC's predecessor. The Consent Agreement resolved One Call's alleged violations of
Rule 102.01 of the Commission Operator Services and Pay Telephone Rules. To resolve this
matter One Call made a $1 000 contribution to the State s General Fund and agreed to not
engage in any future acts, practices or omissions that would constitute violations of Idaho Code
Title 62 or the Commission Rules.Consent Agreement at 2.Furthermore, the Consent
Agreement provided that should One Call be found to be operating contrary to the terms of
Agreement the Commission shall file a complaint in the appropriate district court in support of a
request that such court enter a preliminary and permanent injunction against One Call'
operations. Id.
III.
CAUSES OF ACTION
The Commission Staff alleges OCMC violated the requirements of Rule 104.04 of
the Commission s Operator Services and Pay Telephone Rules by failing to provide the required
disclosures to the called party on 12 938 completed intrastate collect calls made from payphones
in Idaho that OCMC provides OSP services for between March 15 2002 until July 31 2003.
The Commission Staff alleges that OCMC violated the terms of its own Price List by
failing to provide the called party on 12 938 intrastate collect calls the opportunity to receive
information about charges for a connected call between March 15 , 2002 and July 29 2003.
PRAYER FOR RELIEF
Complainant Staff requests that the Commission hold an evidentiary hearing to
determine whether OCMC has violated Rule 104.04.
At the conclusion of evidentiary proceedings Complainant Staff requests that the
Commission find: 1) that OCMC failed to comply with the Commission s Operator Services and
Pay Telephone Rule 104.04 between March 15, 2002 until July 29, 2003; 2) failed to seek a
waiver from the application of the above Rules to its services; and 3) failed to comply with the
terms of its own Price List. Staff also requests that the Commission determine the number of
times that OCMC failed to comply with this Rule and its Price Lists by equating one violation
per one collect call connected by OCMC during the applicable time period.
Given the prior Consent Agreement Staff also requests that the Commission upon
finding that OcMc has violated its Rules, direct the attorney for the Commission to file an
action, pursuant to Idaho Code 9 62-620 in the District Court to seek the imposition of penalties
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
for the number of times the Company has failed to comply with Rule 104.04 of the
Commission s Operator Services and Pay Telephone Rules and for any violations concerned
with failing to comply with the terms of its Price List, unless the Company agrees to remit an
appropriate civil penalty to the Commission for the General Fund of the State ofIdaho.
Such other and further relief as the Commission deems just and proper.
Respectfully submitted this 15th day of March 2004.
M:GNRTO404jh
/L-
John R:f:t:ondDepu- rney General
STAFF'S PETITION TO
INITIATE AN INVESTIGATION
McDevitt & Miller LLP
Lawyers
[phone]
[phone] (Fax)
420 West Bannock Street
O. Box 2564-83701
Boise, Idaho 83702
:\J.171,'I..... '
.... ,
't U F!LED
2I~filOCT -2 PM!:t: Ie
Chas. F. McDevitt
iDAHO PUBb~~n J. (Joe) Miller
UrfUTIE S COMMISSION
October 1, 2003
John Hammond, Esq.
IDAHO PUBLIC UTILITIES COMMISSION
472 West Washington Street
Boise, Idaho 83702
Re: One Call Communications
Dear John:
In response to the questions in your letter of September 19, 2003 , OCMC has provided to me, for transmittal
to you, the following:
1. Programming changes-automated collect calls: OCMes records do not reveal the precise date. It
would have been after Wayne Hart's July 3rd letter and before Ms. Clores July 16th letter.
2. Script implementation date: July 29 2003.
3. Copy of Script: A copy is attached.
3. Call Data starting March 12, 2002:
From Mar 14 2002 through July 31, 2003
Idaho intralata/intrastate AUTO collect totals: 9 021 calls
Idaho intralata/intrastate LIVE collect totals: 3 872 calls
5. OCMC inserted a message into the call tour program. The message is automatic.
6. OCMC drafted the script after making test calls to other operator service providers. The script
was written and inserted into the operator screens. The operators also received a bulletin reminding them
to read their screen. This was a dialog change and was handled like all dialog changes. The operators aretrained to read their screens.
I trust this information is responsive to your requests.
Very truly yours
McDEvm Cst MIllER liP
, Jvean . Miller
DJM/sg
Attach,
C: Ann Bernard
"",
Rate Quote Dialo~
July 29 , 2003
EXPLANATION:You will begin to receive call screens that contain special "rate quote
dialogue that is to be recited to the destination party. The new dialogue will
appear in the Ask! Answer Dialogue" box and is to be used when asking for
the acceptance of charges:
PROCEDURE:This is the Opticom Operator. A rate quote is available upon request.
I have a collect call from . Will you accept the charges?"
Full service
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 15TH DAY OF MARCH 2004, SERVED
THE FOREGOING STAFF'S PETITION TO INITIATE AN INVESTIGATION IN CASE
NO. GNR-04-, BY MAILING A COpy THEREOF POSTAGE PREPAID TO THE
FOLLOWING:
ANN C. BERNARD
OCMC, INC.
801 CONGRESSIONAL BLVD.
CARMEL, IN 46032
E-mail: ann.bernard~oc1d.com
DEAN 1. MILLER
McDEVITT & MILLER, LLP
420 W. BANNOCK STREET
PO BOX 2564 - 83701
BOISE, ID 83702
E-mail: ioe~mcdevitt-mi11er.com
CT CORPORATION
300 N. 6TH STREET
BOISE, ID 83702
SECRETARY
CERTIFICATE OF SERVICE